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Recurrent funding for
2021-22
Outcomes of consultation
Reference OfS 2021.26
Enquiries to [email protected]
Publication date 20 July 2021
1
Contents
Summary 2
Next steps 3
Introduction 4
Context for the consultation proposals 5 Summary of the consultation proposals 7 Further terms and conditions of grant applied by government 8
Overview of consultation responses and OfS position 9
Prioritising activities and funding 9
OfS decisions 10
Elements of recurrent grant for academic year 2021-22 10 Students from the Crown Dependencies 12 High-cost subject funding 12 Funding to improve access and support successful student outcomes 13 Other targeted allocations 14 Changes to terms and conditions of grant for 2021-22 16
Annex A: Analysis of consultation responses on recurrent funding for 2021-22 and summary of OfS decisions 18
Overview of consultation process and responses 18 Analysis of responses to each question and OfS decisions 22
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Summary
1. ‘Consultation on recurrent funding for 2021-22’ (OfS 2021.01) sought views on the Office for
Student’s approach to distributing non-capital grants for academic year (August to July)
2021-22 and terms and conditions that should apply to some elements of grant.1 This
document sets out our analysis of the responses we received to the consultation, our own
response to the views expressed by consultees and the decisions that we have taken on
recurrent funding for academic year 2021-22. We received 8,072 responses to our
consultation, which we have shared with the Department for Education, along with our analysis
of them.
2. Our decisions follow:
a. Having regard to the Secretary of State for Education’s letter of 19 January 2021, setting
out details of the funding available to us for distribution to providers for the financial year
(April to March) 2021-22 and the government’s funding policies and priorities.2
b. Receipt of the Secretary of State’s letter of 25 March 2021, applying terms and conditions
of grant in relation to funding for world-leading specialist providers for 2021-22.
c. Consideration of the responses to our consultation in OfS 2021.01.
d. Receipt of a further letter from the Secretary of State of 19 July 2021, setting out further
terms and conditions of grant. These require us to implement two particular proposals on
which we had consulted, albeit with a modification:
i. We must reduce by 50 per cent the high-cost subject funding rate of grant for performing
and creative arts and media studies. However, the Secretary of State has identified
archaeology as a strategically important subject that should no longer be subject to this
reduction.
ii. We must not vary rates of grant, directly or indirectly, on the basis of the region of the UK
in which a provider or its students are located or courses offered. This means we can no
longer provide allocations or weightings that recognise the additional costs to providers of
operating in London.
3. In light of the grant settlement we received from government for financial year 2021-22, the
terms and conditions of grant that have been placed on us by the Secretary of State, the
responses we received to our consultation and having regard to our duties under the Higher
Education and Research Act 2017 and the Equality Act 2010, we confirm that we are
implementing the proposals set out in our consultation in OfS 2021.01, with the exception of
the treatment of archaeology in the high-cost subject funding method. Archaeology will be
assigned to price group C1.1 and receive a 4 per cent uplift to its rate of grant, rather than price
group C1.2, which would have resulted in a 50 per cent reduction.
1 See www.officeforstudents.org.uk/publications/consultation-on-recurrent-funding-for-2021-22/.
2 Guidance letters to the OfS from the Secretary of State are available from:
www.officeforstudents.org.uk/advice-and-guidance/regulation/guidance-from-government/.
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Next steps
4. On Thursday 29 July, we intend to issue, via the OfS Portal, the recurrent grant letters and
tables for 2021-22 for individual providers, together with technical guidance and a summary
publication showing allocations for all providers. This information will then be publicly released
on our website on 30 July.
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Introduction
5. On 19 January 2021, the Secretary of State for Education wrote to the Office for Students
(OfS) setting out details of the funding available to us for distribution to providers for the
financial year (April to March) 2021-22 and the government’s funding policies and priorities.3
That statutory guidance letter set out a number of changes that the government wished to see
in how the OfS distributes recurrent grant.
6. On 25 March 2021, we received a further statutory guidance letter from the Secretary of State
also applying terms and conditions to funding to be allocated to world-leading specialist
providers.4 This specified further requirements that we must meet relating to £43.4 million
currently distributed to 16 world-leading specialist providers plus an additional £10 million.
7. On 26 March 2021, we issued a consultation on our proposed approach to recurrent funding for
the academic year (August to July) 2021-22.5 Alongside our consultation, we provided detailed
modelling of the impact of the various funding proposals on universities and colleges, both to
help their planning and inform all those wishing to respond. This modelling considered the
effect on providers’ funding if all the proposals in the consultation were to be implemented, as
well as of their latest student numbers. The consultation ran until 6 May 2021.
8. We invited responses to the consultation through an online form, which included 16 questions,
of which 13 asked respondents to select the extent to which they agreed or disagreed with
particular proposals, or whether they ‘did not know/preferred not to say’. These 13 questions
also invited respondents to provide comments setting out the reasons for their view and, if they
disagreed with a proposal, how we should change our approach and why. The other three
questions invited comments only.
9. The online form asked respondents to submit their responses (by clicking a button), once they
had completed question 16. Where they did so, we consider these to be ‘full responses’. Where
respondents answered consultation questions but did not click ‘submit’, we consider these to
be ‘partial responses’ – such responses may not have answered all 16 questions. Our analysis
has considered both full and partial responses, which together total 8,072 submissions. This
publication reports on the responses we have received and the decisions we have taken on the
approach to recurrent funding for academic year 2021-22.
3 The January 2021 statutory guidance letter is available at: www.officeforstudents.org.uk/advice-and-
guidance/regulation/guidance-from-government/.
4 The March 2021 statutory guidance letter is available from the same webpage as the January letter.
5 See www.officeforstudents.org.uk/publications/consultation-on-recurrent-funding-for-2021-22/.
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Context for the consultation proposals
10. The government’s statutory guidance letter in January 2021 announced a non-capital grant for
financial year 2021-22 of £1,330 million, an £11 million increase compared with the previous
year. Table 1 shows the grants provided for 2021-22 and the previous two years.6
Table 1: Government grants to the OfS (£ millions)
Financial year 2019-20 2020-21 2021-22
Strategic priorities grant 1,387 1,329 1,330
Less funding distributed through Research England7 -58 -57 -47
Capital grant 100 150 150
Total for distribution by the OfS 1,429 1,422 1,433
One-off non-capital grants 80 15
One-off capital grant for 2020-21 10
11. Our consultation proposed to distribute £1,287 million in non-capital grants for the academic
year 2021-22. Of this total, we proposed £21 million as funding for national facilities and
regulatory initiatives (primarily comprising funding for Challenge Competitions, Jisc and the
National Student Survey), leaving £1,266 million in recurrent funding for providers and for Uni
Connect. Table 2 summarises funding distributed by the OfS for academic years 2019-20 and
2020-21 and that we proposed for 2021-22.8
Table 2: Overall budget for academic years 2019-20 to 2021-22 (£ millions)
Academic year 2019-20 2020-21 2021-22
Recurrent grant9 1,303 1,256 1,266
National facilities and regulatory initiatives 29 21 21
Total recurrent funding 1,332 1,277 1,287
Capital funding 100 150 150
Total funding distributed by the OfS 1,432 1,427 1,437
One-off non-capital funding for 2020-21 95
6 This table has been updated compared with Table 1 in the consultation published as OfS 2021.01 to reflect
one-off funding of £15 million that has since been provided by government to address student hardship in the
period April to July 2021 (covering the four-month overlap between financial year 2021-22 and academic
year 2020-21. See: www.officeforstudents.org.uk/publications/student-hardship-funding-monitoring-and-
additional-allocation/.
7 The non-capital grant totals for each year include funding distributed through Research England, rather
than the OfS. This comprises £47 million for the Higher Education Innovation Fund and, for 2019-20 and
2020-21 only, funding for the University of London School of Advanced Studies and the Institute of Zoology.
8 This table has also been updated compared with Table 2 in the consultation published as OfS 2021.01 to
reflect the one-off funding of £15 million that has since been provided by government to address student
hardship in the period April to July 2021. See footnote 6.
9 Recurrent teaching comprises the main formula allocations for providers plus funding for Uni Connect.
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Academic year 2019-20 2020-21 2021-22
One-off capital funding for 2020-21 10
Note: Sums may not add up due to rounding differences.
12. The increase in total recurrent funding of £10 million (0.8 per cent) compared with 2020-21 has
to support a significant increase in student numbers.10 Table 3 summarises the changes to the
full-time equivalent student numbers (FTEs) counting towards our recurrent funding allocations
between 2020-21 and 2021-22.11 The inclusion for 2021-22 of students from the Crown
Dependencies was a proposal on which we sought views in our consultation.
Table 3: FTEs counting towards OfS recurrent funding for providers for academic years 2020-21 and 2021-22
Price group A
Price group B
Price group C1
Price group C2
Price group D
Total
Counted for 2020-21 26,742 253,780 254,910 246,206 441,045 1,222,683
HESES20 27,283 272,088 269,494 256,280 474,620 1,299,765
Planned increases in medicine
1,320 180 0 0 0 1,500
Crown Dependencies 54 603 629 720 954 2,960
Other adjustments 236 808 234 26 57 1,361
Total counting for 2021-22
28,893 273,679 270,357 257,026 475,631 1,305,586
Change 2020-21 to 2021-22
2,151 19,889 15,447 10,820 34,586 82,903
13. Table 3 shows increases in FTEs compared with 2020-21 of:
• 6.8 per cent across all price groups A to D.
• 7.0 per cent in the high-cost price groups A, B and C1.
• 8.0 per cent in the highest cost price group A applying to clinical subjects in medicine and
dentistry.
14. Set against the increase in funding of 0.8 per cent, the significant increase in student numbers
for 2021-22 means that there is a reduction to the average funding that we are able to provide
10 The £10 million increase in recurrent funding for 2021-22 disregards the one-off funding of £95 million
provided for 2020-21.
11 This table has been updated compared with Table 3 in the consultation published as OfS 2021.01 to
reflect an overall increase of 585 to the intake targets for pre-registration courses in medicine and dentistry
for 2021-22, compared with those previously planned (included under ‘other adjustments’ in price group B),
plus a small number of other minor changes to the data for providers. See:
www.officeforstudents.org.uk/advice-and-guidance/funding-for-providers/health-education-funding/medical-
and-dental-target-intakes/.
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per FTE. Our consultation estimated the reduction in OfS funding per FTE between 2018-19
and 2021-22 to be 19.3 per cent in real terms.12
Summary of the consultation proposals
15. In the light of our funding settlement from government for the coming financial year, the
significant increase in student numbers that this funding must support, and the wider
circumstances affecting higher education arising from the pandemic, our consultation proposed
that the primary policy aims in distributing recurrent grant for academic year 2021-22 should
be:
a. To protect, and if possible enhance, the rate of grant per FTE provided through the main
high-cost subject funding method and the nursing, midwifery and allied health supplement,
particularly where these support science, technology, engineering and mathematics
(STEM) subjects and healthcare disciplines.
b. To enhance the total funding targeted at specialist providers, recognising the distinctive role
they play in meeting the needs of students and particular specialist employment sectors.
c. To protect as far as possible the total funding that we allocate towards providers’ activities
to improve access and support student success.
16. These policy aims have implications for the funding that we can commit to other elements of
grant. The consultation therefore invited comments on the following specific proposed changes:
a. An increase to the funding distributed through the main high-cost subject funding method
for subjects in price groups A, B and some in price group C1 (for courses in pre-registration
nursing and in computing and information technology).
b. A reduction by half to the rate of high-cost subject funding for other price group C1 subjects
– that is, for courses in performing and creative arts, media studies and archaeology.
c. The inclusion of students from the Crown Dependencies as countable for OfS funding
purposes.
d. The withdrawal of the targeted allocation for students attending courses in London.
e. The removal of London weighting from the student premium allocations.
f. An increase of £10 million to funding that supports specialist providers.
12 An analysis of changes over time to the unit of resource (which takes account of both OfS grants and fee
income per FTE) was provided in Annex B of the OfS board paper on funding in September 2020 (agenda
item 10), available at: www.officeforstudents.org.uk/about/board-papers/ofs-board-meeting-22-september-
2020/. The unit of resource has been declining since 2015-16 as a result not only of reductions to OfS
grants, but also because the value of the regulated course fee limit has not been maintained. Using the
government’s measure for inflation that will maintain the value of course fees in real terms (the Retail Prices
Index All Items Excluding Mortgage Interest Repayments: RPIx), had the regulated course fee limit for full-
time undergraduates of £9,000 introduced in 2012-13 been maintained in real terms, the fee limit for 2021-22
would have been nearly £11,200, rather than the £9,250 that actually applies. This is a reduction in real
terms of over 17 per cent over the period.
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g. A reduction of £20 million to the funding provided for Uni Connect.
h. An allocation of £5 million for student hardship.
i. Funding of £15 million to support student transitions and mental health.
17. We were not consulting on the total amount of funding available for distribution by the OfS for
the 2021-22 academic year. This is determined by the amount of grant made available to us by
government.
Further terms and conditions of grant applied by government
18. We received 8,072 submissions that responded to at least one of our consultation questions
and Annex A provides our summary analysis of them. As our consultation stated we would, we
have shared all consultation responses, as well as our summary analysis of them, with the
Department for Education.
19. On 19 July, we received a further statutory guidance letter and terms and conditions of funding
from the Secretary of State.13 The practical effect of the particular terms and conditions which
have been imposed is that the OfS is obliged:
a. To reduce by 50 per cent the rate of grant provided through the high-cost subject funding
method for certain subjects that have not been specified in the list of priority subjects set
out in the terms and conditions. The subjects that will have this reduction are those in
performing and creative arts and media studies. Archaeology will not be subject to this
reduction (in contrast to the proposal in our consultation). Further, the terms and conditions
prevent us taking account of the cut to high-cost subject funding for these subjects through
other allocations without the written agreement of the Department for Education.
b. Not to vary the rates of any grant on the basis of the region in which a provider, its courses
or students are located. This condition precludes the provision of London weighting in our
formula allocations.
20. The terms and conditions of grant imposed on us under section 74 of the Higher Education and
Research Act 2017 (HERA) require us to allocate the funds as set out in that document.14 If we
do not comply with the terms and conditions that the Secretary of State has imposed then we
may be required to repay the whole or any part of the grant still held by us to the Department of
Education. We therefore confirm that for 2021-22:
a. We will split price group C1 between C1.1 (covering pre-registration courses in nursing,
provision relating to computing and information technology, and archaeology) and C1.2
(other price group C1 subjects, covering provision in performing and creative arts and
media studies). The high-cost subject funding rate of grant for provision in price group C1.2
will be £121.50 per FTE, a reduction of 50 per cent compared with 2020-21.
13 The 19 July 2021 statutory guidance letter is also available at: www.officeforstudents.org.uk/advice-and-
guidance/regulation/guidance-from-government/.
14 See: www.legislation.gov.uk/ukpga/2017/29/section/74/enacted.
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b. We will no longer provide the targeted allocation for students attending courses in London,
nor include a London weighting in any other formula grant (London weighting was
previously included in the calculation of student premiums within recurrent grant and in
formula capital grants).
Overview of consultation responses and OfS position
21. Annex A provides our summary analysis of the 8,072 submissions that responded to at least
one of our consultation questions. It provides a summary of the numbers responding to each
question and of those agreeing, disagreeing or neither to particular proposals and it draws out
the themes in the comments that respondents made. It also incorporates OfS responses to
particular points made in consultees’ submissions.
22. The number of responses we received to our consultation is unprecedented, but we welcome
the interest shown in it. We believe the very high number was prompted by discussion on
social media in the final week of the consultation period, which encouraged responses in
particular to campaign against cuts to funding for arts subjects. This is reflected in the number
of submissions that adopted the use of template responses and, indeed, in the very large
numbers expressing disagreement with our proposals to cut funding for the arts. The strength
of feeling expressed by the large majority of respondents on this is clear. However, there is no
duty to adopt the submissions of respondents to a consultation; rather, the OfS is entitled to
consider the whole range of responses and form its own conclusion independently of the view
of any particular section of consultees. Where respondents have disagreed with a proposal that
we are nonetheless taking forward, we have explained why that proposal is being taken
forward despite those responses received.
Prioritising activities and funding
23. Many respondents’ answers to the various questions were characterised by their views on one
particular issue – in particular on the proposed cut to arts funding or removal of funding that
recognises the additional costs of operating in London. Even where they may have indicated
agreement on other proposals, this was often qualified on the condition that those other
proposals were not at the expense of funding for the arts or for London. Nevertheless, there
was also often a tendency to treat questions in isolation, rather than as a set of interlinked
proposals. Indeed, those arguing against cuts to arts funding, particularly when using template
responses, argued that it should be subject to its own consultation. We could not do this.
24. The total funding available for the academic year 2021-22 is fixed, as it is driven by the money
made available to us by government. This means that if we were to change the budget
proposals for one element of grant, it would change that available for one or more others. This
also applies to arguments that changes should be phased in over a longer period: this also has
a cost that would affect how much we could provide for other budgets.
25. Our consultation was about the distribution of £1,287 million of public funding for academic
year 2021-22. We proposed a particular set of options for consultation that were designed to
strike an appropriate balance, within a fixed budget, between a variety of different priorities as
well as between our various duties, and all set in the context of significantly increasing student
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numbers and the effects of the pandemic on students, higher education providers and the
wider economy and society.
26. A number of respondents argued that certain proposals in our consultation were in conflict with
our duties under section 2 of HERA. Respondents referred to the OfS’s duties ‘to promote
greater choice and opportunity for students’ or ‘to promote equality of opportunity’ This does
not correctly reflect the OfS’s duties. Our duties under section 2 of HERA require that we ‘have
regard to’ the need to do various things, and the public sector equality duty is similarly framed
in terms of having ‘due regard to the need to’.15 A particular duty does not prescribe what
course of action we must follow in relation to a particular policy or issue, nor does it necessarily
prohibit any particular approach. Rather, it requires that we give each of our duties due
consideration when determining a course of action – essentially weighing one against the
other, striking a balance between them as we consider appropriate.
27. The issues of the proposed cuts to high-cost subject funding for performing and creative arts,
media studies and archaeology and, to a lesser but still significant extent, London weighting
dominated the responses that we received to the consultation – both in relation to the specific
questions on them, and other questions. The condition of grant that the Secretary of State
placed on us on 19 July 2021 has determined our funding approach on those two issues.
OfS decisions
28. Annex A summarises the views expressed by respondents to our consultation and sets out OfS
responses to those views and the reasons for our decisions. Those decisions are set in the
context of the fixed budget we have available for distribution and the terms and conditions of
grant applied by the Secretary of State on the cuts to funding for performing and creatives arts
and media studies, the withdrawal of London weighting and the funding to be made available to
world-leading specialist providers. In reaching our decisions, we have also had regard to our
duties under HERA and the Equality Act 2010.
Elements of recurrent grant for academic year 2021-22
29. This section summarises all our decisions on non-capital grants for academic year 2021-22.
These will total £1,287 million, comprising £21 million for national facilities and regulatory
initiatives and £1,266 million in recurrent grants for providers and Uni Connect. Funding for
national facilities and regulatory initiatives primarily comprises funding for Challenge
Competitions, Jisc and the National Student Survey and the £21 million total is the same in
cash terms as was provided for 2020-21.
30. Table 4 sets out the disaggregation of funding between different elements of grant for
academic year 2021-22. The figures have been updated compared with those shown in Table
5 of OfS 2021.01 to reflect the changed assignment for archaeology to price group C1.1
instead of C1.2, and to reflect the distribution of a further £15 million provided for student
hardship for the period April to July 2021 (within the 2020-21 academic year).
15 See: www.legislation.gov.uk/ukpga/2010/15/section/149.
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Table 4: Recurrent grant budgets for academic year 2021-22 (£ millions)
Elements of recurrent grant 2020-21 budget
2021-22 budget
Percentage change to budget
Funding for high-cost courses 896 899 +0%
Of which:
High-cost subject funding: price groups A and B; pre-registration nursing; computing and information technology; archaeology
656 737 +12%
High-cost subject funding: performing arts; creative arts; media studies16
35 18 -49%
Nursing, midwifery and allied health (NMAH) supplement
23 27 +16%
Sub-total high-cost subject funding and NMAH supplement
715 782 +9%
Very high-cost STEM subjects 24 24 0%
Overseas study programmes 28 28 0%
Postgraduate taught supplement 8 8 0%
Intensive postgraduate provision 33 33 0%
Accelerated full-time undergraduate provision 4 4 0%
Students attending courses in London 64 0 -100%
Clinical consultants’ pay 16 16 0%
Senior academic general practitioners’ pay 1 1 0%
NHS pensions scheme compensation 5 5 0%
Funding for student access and success 316 313 -1%
Of which:
Premium to support successful student outcomes: Full time17
150 154 +2%
Premium to support successful student outcomes: Part time
66 67 +1%
Disabled students’ premium 40 41 +2%
Premium for student transitions and mental health
0 12 New
Uni Connect 60 40 -33%
Funding for specialist providers 43 53 +23%
Specialist institutions 43 53
Total recurrent grant 1,256 1,266 +1%
16 The terms and conditions noted in paragraph 19 require us to reduce the rate of funding for these subjects
by 50 per cent. Due to increases in the number of students in these subjects, the change to the budget
required is -49 per cent.
17 The funding for the three student premiums for 2021-22 incorporates the distribution of £5 million to be
earmarked to address student hardship.
12
Elements of recurrent grant 2020-21 budget
2021-22 budget
Percentage change to budget
One-off recurrent funding for high-cost subjects and NMAH supplement for 2020-21
10 0
One-off funding for student hardship in 2020-21 allocated based on student premiums
85 0
Total recurrent grant including one-off sums 1,351 1,266
Note: Sums may not add up due to rounding differences.
Students from the Crown Dependencies
31. The government has decided that from 2021-22, students from the Crown Dependencies (the
Channel Islands and the Isle of Man) will be eligible for home fee status.18 Undergraduates will
also (subject to other criteria) commonly also be subject to regulated fee limits. These changes
apply to such students in all years of study, not just entrants, but providers should note that
they do not apply to students from the Crown Dependencies that are studying by distance
learning, unless they are doing so within the UK (rather than from the islands).
32. As proposed in our consultation, we will count students from the Crown Dependencies that are
subject to these fee regulation changes for all formula-based recurrent grant allocations that
are recalculated each year to reflect the latest student numbers (not just to high-cost subject
funding). To implement this, we will adjust the student numbers we count by adding on the
numbers of relevant students from the Crown Dependencies that we identify in the
individualised student data returns for 2019-20 (by price group, mode and level, as needed).
High-cost subject funding
33. Annex B of OfS 2021.01 identified the subject codes that we proposed should map to the new
price group C1.2. This price group applies to subjects in the performing and creative arts and
media studies that are to be subject to the 50 per cent reduction (-£121.50) to the rate of grant
for high-cost subject funding. We confirm that the subject codes that map to price group C1.2
for funding purposes from 2021-22 are as proposed in our consultation, but with the exception
of codes relating to archaeology, which will now map to price group C1.1 instead of C1.2.19
34. The changes to budgets for high-cost subject funding, combined with changes to the FTEs that
we count, and the decision to halve the rate of funding for subjects that map to the new price
group C1.2 result in changes to rates of high-cost subject funding as shown in Table 5. The
figures in Table 5 have reduced slightly for price groups A, B and C1.1 compared with the
equivalent Table 6 in OfS 2021.01 to reflect an overall increase of 585 to the intake targets for
pre-registration courses in medicine and dentistry for 2021-22 (included in price group B at a
cost of a little under £1 million), the decision to assign archaeology to C1.1 instead of C1.2 (at
18 Students from the Crown Dependencies have been eligible for home fees if they were already living and
working in the UK. The change from 2021-22 is to make those resident in the islands before the start of their
course also eligible for home fees.
19 The archaeology subject codes that this applies to are, for further education and sixth form colleges, the
Learn Direct Classification System (LDCS) code DC and, for other providers, the Common Aggregation
Hierarchy (CAH) code CAH20-01-03.
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a cost of a little over £250,000), plus a small number of other minor changes to the data for
providers.20 The scaling factor for 2021-22 is set at 1.01 (rather than 1.011 as set out in OfS
2021.01), although this still rounds to a 4 per cent increase compared with the scaling factor of
0.972 for 2020-21.
Table 5: Changes to high-cost subject rates of funding for 2021-22
Price group Funding rate per FTE
for 2020-21 Funding rate per FTE
for 2021-22 Percentage
change
A £9,720 £10,100 +4%
B £1,458 £1,515 +4%
C1.1 £243 £252.50 +4%
C1.2 £243 £121.50 -50%
C2 £0 £0 N/A
D £0 £0 N/A
Funding to improve access and support successful student outcomes
35. Table 4 shows the changes to 2021-22 budgets for various allocations to improve access and
support successful student outcomes. The methodological changes we are making to formula
allocations are as follows:
a. We are no longer including London weighting in the calculation methods for student
premiums, reflecting the condition of grant placed on us by the Secretary of State of 19 July
2021.
b. A total of £5 million allocated through the student premiums will be identified as funding to
address student hardship, which must be distributed to students. We will treat this hardship
funding as a single allocation, albeit that we will identify the total for each institution such
that the total for the sector as a whole is drawn from the three premiums as follows:
i. £775,000 (15.5 per cent) through the disabled students’ premium.
ii. £3,750,000 (75 per cent) through the full-time student premium.
iii. £475,000 (9.5 per cent) through the part-time student premium.
c. In previous years, the allocation of disabled students’ premium funding has been capped so
that no provider received a change of more than £200,000 compared with the previous
year. We will not apply any such cap to the allocations for 2021-22.
d. We are introducing a new £12 million formula allocation to support students’ transition into
higher education, addressing the challenges to student mental health for those at the
20 See: www.officeforstudents.org.uk/advice-and-guidance/funding-for-providers/health-education-
funding/medical-and-dental-target-intakes/. Paragraph 6b of OfS 2021.01 explained that we proposed to
count any such increase to intake targets for 2021-22.
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beginning of their undergraduate studies, including through supportive and preventative
measures that help to maintain good mental health and prevent more serious problems
arising. We will distribute this funding pro rata to the headcount of OfS-fundable
undergraduate entrants, as reported in HESES20.21
36. In addition to the formula allocations we are also allocating:
a. £40 million for Uni Connect partnerships (a reduction of £20 million compared with 2020-
21).
b. £3 million as part of the £21 million total for national facilities and regulatory initiatives to
support student mental health. We will distribute this in part by a £2 million increase to the
sum available through the recent competition for funds provided by the Department of
Health and Social Care,22 and in part through an extension of the online services of Student
Space,23 and through a national programme to mobilise recent existing effective practice to
support student mental health throughout the sector.
Other targeted allocations
37. As a result of the condition of grant placed on us by the Secretary of State of 19 July 2021, we
are no longer providing the targeted allocation for students attending courses in London from
academic year 2021-22.
38. We are maintaining in cash terms the rates of grant allocated through the nursing, midwifery
and allied health supplement. Table 6 summarises those rates of grant per FTE.
Table 6: Price groups and rates of funding per FTE for the nursing, midwifery and allied health supplement
Profession Price group
Rate of funding per undergraduate FTE (£)
Rate of funding per postgraduate FTE (£)
Dental hygiene A 0 0
Dental therapy A 0 0
Dietetics B 79.50 779.50
Midwifery B 79.50 779.50
Nursing – adult C1 213.25 913.25
Nursing – children C1 413.25 1,113.25
21 For providers that will be funded for the first time in 2021-22 based on data submitted to the HESF21
survey, we will use their forecast undergraduate data for the year. As with other allocations, their allocation
will be recalculated later in the year to reflect the OfS-fundable undergraduate entrants they report in the
HESES21 survey.
22 See: www.officeforstudents.org.uk/advice-and-guidance/funding-for-providers/mental-health-funding-
competition/.
23 See: studentspace.org.uk/about-student-space.
15
Profession Price group
Rate of funding per undergraduate FTE (£)
Rate of funding per postgraduate FTE (£)
Nursing – learning disability C1 413.25 1,113.25
Nursing – mental health C1 213.25 913.25
Nursing – unclassified C1 213.25 913.25
Occupational therapy B 79.50 779.50
Operating department practice B 79.50 779.50
Orthoptics B 3,579.50 4,279.50
Orthotics and prosthetics B 3,579.50 4,279.50
Physiotherapy B 79.50 779.50
Podiatry B 1,279.50 1,979.50
Radiography (diagnostic) B 1,279.50 1,979.50
Radiography (therapeutic) B 1,279.50 1,979.50
Speech and language therapy B 279.50 979.50
39. We will also maintain in cash terms the £2,315 rate of grant provided to support study years
abroad, including those taken under the government’s new Turing Scheme.24 We will distribute
this funding using the higher of the numbers taking such a year abroad in either 2019-20 or
2020-21. The 2020-21 data on study years abroad shows a very significant reduction in
participation, because of the effects of the pandemic. We believe this data is likely to be
unrepresentative of future participation, but that we should also recognise where (a very small
number of) providers have reported an increase in numbers in 2020-21.
40. We are maintaining in cash terms the budgets for the other targeted allocations that were
funded for 2020-21. Some of these allocations are not recalculated each year to reflect the
latest student FTE data, and for these, providers will receive the same cash allocation in
2021-22 as for 2020-21.25 For other allocations, changes to student numbers reported for
2020-21 will mean there will be a variable impact on the rates of funding per FTE that we are
able to provide. This is summarised in Table 7.
24 See: www.turing-scheme.org.uk/.
25 This applies to the allocations for very high-cost STEM, clinical consultants’ pay, senior academic general
practitioners’ pay, and NHS pension-scheme compensation.
16
Table 7: Changes to rates of funding for targeted allocations
Allocation Rate of grant per FTE for 2020-21
Rate of grant per FTE for 2021-22
Percentage change to rate of funding per FTE
Postgraduate taught supplement26 £1,009.23 £1,023.08 +1%
Intensive postgraduate provision27
Price group B £1,044.20 £895.75 -14%
Price groups C1 and C2 £798.51 £684.99 -14%
Accelerated full-time undergraduate provision28
Price group B £1,273.90 £1,149.77 -10%
Price groups C1 and C2 £974.16 £879.24 -10%
Price group D £749.35 £676.34 -10%
Changes to terms and conditions of grant for 2021-22
41. In OfS 2021.01, we consulted on two particular changes to the terms and conditions of grant
for 2021-22 relating to new elements of recurrent grant – the £5 million to be allocated through
the existing student premiums for student hardship (see paragraph 35.b) and the £12 million to
be allocated as a new premium for student transition and mental health (see paragraph 35.d).
These elements of grant will be identified in providers’ recurrent grant tables for 2021-22 and
we confirm that, following consultation, they are subject to the following specific terms and
conditions:
a. Hardship funding for 2021-22. This element of grant is earmarked for distribution in the
academic year to students aiming for a higher education qualification who are facing
hardship, particularly where it is needed to support their continuation of study and
successful outcomes. It must not be used to meet providers’ own costs. We reserve the
right to recover any hardship funding that is not used for the purposes intended.
b. Premium for student transition and mental health. This element of grant is earmarked
for activities and services of providers that support students transitioning into higher
education, particularly to address the challenges that this can present for mental health.
42. In OfS 2021.02 we also consulted on certain changes to terms and conditions of grant relating
specifically to capital funding for providers. ‘Capital funding for financial year 2021-22:
26 The postgraduate taught supplement applies to postgraduate students in price groups A, B, C1 and C2
that are on courses for which neither masters loans nor loans under the undergraduate student support
arrangements are available.
27 The targeted allocation for intensive postgraduate provision applies to postgraduate students in price
groups B, C1 or C2 who are studying for at least 45 weeks in the year full-time, or the equivalent part-time.
28 The targeted allocation for accelerated full-time undergraduate provision applies to undergraduate
students in price groups B, C1, C2 or D who are studying for at least 45 weeks in the year full-time.
17
Allocations and invitation to bid’ (OfS 2021.27) confirms terms and conditions that apply to
capital grants for 2021-22.29
43. We will publish separately ‘Terms and conditions of funding for 2021-22’, incorporating these
changes (as well as routine updates to years and cross-references compared with those for
2020-21).
29 See www.officeforstudents.org.uk/publications/capital-funding-for-financial-year-2021-22-allocations-and-
invitation-to-bid/
18
Annex A: Analysis of consultation responses on recurrent funding for 2021-22 and summary of OfS decisions
Overview of consultation process and responses
1. On 19 January 2021, the Secretary of State for Education wrote to the Office for Students
(OfS) setting out details of the funding available to distribute to providers for the financial year
(April to March) 2021-22 and the government’s funding policies and priorities.30 Publication of
this statutory guidance letter was part of a coordinated series of announcements on higher
education and skills policy made by government on 21 January 2021 and on which the
Secretary of State made an announcement to Parliament.31 That day, we issued a news item,
which we sent to an extensive press list of national and sector journalists, as well as
stakeholder groups.32 We also wrote individually to the heads of all the universities and
colleges registered with us alerting them to the contents of the government guidance letter on
funding.33 Finally, we sent an email to all subscribers to OfS Alerts about the announcements,
including on funding for 2021-22.34
2. We issued our consultation on 26 March 2021.35 This included detailed modelling of the impact
of the various funding proposals on universities and colleges, both to help their planning and
inform all those wishing to respond.36 As before, we issued a news item.37 We also emailed
every university and college that we fund to alert them and explain how they could access
further details about our modelling. We also emailed a number of sector representative bodies
and issued another OfS Alert to subscribers.
30 The January 2021 statutory guidance letter is available at: www.officeforstudents.org.uk/advice-and-
guidance/regulation/guidance-from-government/.
31 See hansard.parliament.uk/commons/2021-01-21/debates/7055ACEF-8DB3-4D75-98D4-
66947FEDD64F/SkillsForJobsWhitePaper.
32 See www.officeforstudents.org.uk/news-blog-and-events/press-and-media/ofs-responds-to-government-s-
interim-response-to-augar-review-statutory-guidance-on-funding-and-tef/.
33 See www.officeforstudents.org.uk/publications/ao-letter-ofs-s-response-to-announcements-from-dfe/.
34 Anyone can sign up to these alerts (www.officeforstudents.org.uk/sign-up-for-email-alerts/) which currently
have over 6,500 subscribers, ranging from members of the public to staff working in higher education and
other industries.
35 See www.officeforstudents.org.uk/publications/consultation-on-recurrent-funding-for-2021-22/.
36 Our modelling considered the effect on providers’ funding if all the proposals in the consultation were to be
implemented, as well as of their latest student numbers.
37 See www.officeforstudents.org.uk/news-blog-and-events/press-and-media/regulator-opens-consultations-
on-funding-and-outlines-new-plans-to-improve-outreach-to-disadvantaged-students/.
19
3. The consultation ran until 6 May 2021 and we used OfS Alerts for each of the last three weeks
of the consultation period to remind subscribers about the impending deadline for response.
The consultation was open to all, although we stated that we were particularly (but not only)
interested in hearing from:
a. Higher education providers (of all types and size) that are registered, or are applying to be
registered, with us in the Approved (fee cap) category.
b. Representative bodies of higher education providers and their staff, student representatives
and others with an interest in the finance arrangements for higher education.
4. We invited responses to the consultation through an online form, which included 16 questions,
of which 13 asked respondents to select the extent to which they agreed or disagreed with
particular proposals, or whether they ‘did not know/preferred not to say’. These 13 questions
also invited respondents to provide comments setting out the reasons for their view and, if they
disagreed with a proposal, how we should change our approach and why. The other three
questions invited comments only.
5. The online form asked respondents to submit their responses (by clicking a button), once they
had completed question 16. Where they did so, we consider these to be ‘full responses’. Where
respondents answered consultation questions but did not click ‘submit’, we consider these to
be ‘partial responses’ – such responses may not have answered all 16 questions. However, we
have included both full and partial responses in the summary that follows. Although 20,318
responses were started via the online form, only 8,360 of these included at least one answer to
a consultation question. We have therefore disregarded other responses that did not express a
view on any of the consultation questions. We have also disregarded a further 297 responses,
which duplicate ones that we have considered and included in our summary analysis. We have
identified duplicate responses where:
a. Multiple submissions were made from the same email address.
b. More than one response was made on behalf of an organisation. Typically, this will have
been where a full response was made by the organisation, but where there was also one or
more partial responses.
6. In addition to responses submitted through the online form, we received nine responses via
email, which we have included in our analysis. Table A1 summarises the numbers of
responses that we have incorporated in our review, after disregarding those that did not answer
any questions or were duplicates.
Table A1: Number of responses considered in our summary analysis
Respondent type Full response Partial response Total responses
On behalf of a registered provider 118 5 123
On behalf of other organisation 163 15 178
As an individual 6,242 1,529 7,771
All respondents 6,523 1,549 8,072
20
7. The very large majority of responses were received in the final week of the consultation period.
The exceptional number that we received – particularly from individuals – was likely prompted
by discussion on social media and news outlets that started during the May bank holiday
weekend (1 to 3 May 2021), in particular by comments from, and campaigning by, the
Musicians Union (MU).38 On 6 May, we issued a statement to clarify our proposals relating to
funding for the performing and creative arts, because we were concerned that the scale of the
proposed changes was overstated in some discussions.39
Musicians Union template letter
8. The MU provided template letters which those concerned about our proposals on funding for
the performing and creative arts might use in responding to the OfS and the Department for
Education.40 We received some of these by email, while other respondents incorporated
(elements of) the letter text in completing the online form. The template letter to the OfS set out
concerns about the process of consultation, which we respond to here. There were two main
concerns:41
a. That the consultation was poorly publicised:
‘organisations in the music sector such as the Musicians’ Union were only made aware of it
in late April. Universities and other sector organisations were also unaware of the
consultation until recently. We object to such an important consultation being undertaken
without fair notice given to students, lecturers, universities, employers, creative sector
organisations, heritage sector organisations, and trade unions.’
OfS response: We have set out in paragraphs 1 to 3 of this Annex the steps we took to
publicise both the Secretary of State’s strategic guidance letter and the launch and
impending deadline of our consultation. This included issuing news items to the media,
communications directly with the heads of all universities and colleges registered with
us, and alerts to sector representative bodies and other subscribers. For this reason, we
do not accept that our consultation was poorly publicised and it is incorrect to say that
universities and other sector organisations were unaware of it until late in the
consultation period.
b. That the consultation included only
‘one question on the proposed 50 per cent funding cut to music and arts courses. A 50 per
cent funding cut is a significant and damaging change with huge repercussions for higher
education institutions, students, and the creative industries. It should have been given its
own consultation, not wrapped into a broad and general funding consultation.’
38 See musiciansunion.org.uk/.
39 See www.officeforstudents.org.uk/news-blog-and-events/press-and-media/arts-funding-in-higher-
education/.
40 See: musiciansunion.org.uk/campaigns/government-arts-funding-in-higher-education.
41 See: musiciansunion.org.uk/all-campaigns/make-a-complaint-to-the-office-for-students.
21
OfS response: The overall grant we have available to distribute to higher education
providers is determined by government – we cannot spend more than we receive. For
the 2021-22 academic year, the recurrent grant total is fixed at £1,287 million. The
challenge that our consultation set out was that the total funding has increased by just
under 1 per cent,42 but student numbers have increased by just under 7 per cent (both
overall and in the high-cost subjects that attract most of our funding). It means a
reduction in the average rate of OfS grant per student next year, requiring difficult
decisions about how we prioritise our grant between the universities and colleges that
we fund. Our consultation put forward a package of measures for how we might do this,
which had regard to the strategic guidance letters we received from the Secretary of
State in January 2021, and March 2021.43
Given this context, we could not consider the proposal to cut funding for performing and
creative arts, archaeology and media studies in a separate consultation, because it is
inextricably linked with all the other proposals: how much we spend on one area of
activity affects how much we can afford to spend on others. We recognise there will be
strong and varied views on whether our proposals are right and we welcome them all –
that is what we sought in our consultation. However, with a fixed budget, we have to
make decisions on the overall balance of funding between different providers and
different activities, rather than consider them in isolation.
Analysis of responses
9. Responses to consultation can provide important arguments and evidence about proposals,
their impact and possible alternative approaches. They also provide contextual information
about how widespread and how strong views are on proposals, through the use of Likert-type
responses (such as options to agree or disagree). However, as above, there is no duty to adopt
the submissions of respondents to a consultation; rather, the OfS is entitled to consider the
whole range of responses and form its own conclusion independently of the view of any
particular section of consultees. Where respondents have disagreed with a proposal that we
are nonetheless taking forward, we have explained why that proposal is being taken forward
despite those responses received.
10. As the analysis that follows shows, we received thousands of comments in the responses to
each question and we have read through them all. We have not given greater weight to
comments based on who the respondent is, because our concern is about the strength of the
argument or evidence provided. All responses were read and analysed by OfS staff.
42 This disregards one-off sums totalling £95 million provided for academic year 2020-21. These comprise
£10 million to support increases in student numbers in the year following the re-grading of A-levels and other
Level 3 qualifications in summer 2020; and £85 million to address student hardship arising from the
pandemic.
43 The strategic guidance letter to the OfS of 25 March 2021 applied a condition of grant on the amount and
approach to distributing funding for world-leading specialist providers for academic year 2021-21. The letter
is available from: www.officeforstudents.org.uk/advice-and-guidance/regulation/guidance-from-government/.
22
Analysis of responses to each question and OfS decisions
Question 1: To what extent do you agree with the proposal to distribute a greater proportion of OfS recurrent grant through the main high-cost subject funding method?
11. Table A2 summarises the extent to which respondents to the consultation agreed or disagreed
with the proposal, or neither.
Table A2: Numerical summary of responses to question 1
Respondent type Strongly agree
Tend to agree
Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
23 (19.2%) 35 (29.2%) 23 (19.2%) 33 (27.5%) 6 (5.0%)
On behalf of other organisation
10 (5.9%) 11 (6.5%) 13 (7.6%) 104 (61.2%) 32 (18.8%)
As an individual 193 (2.5%) 191 (2.5%) 471 (6.1%) 5710 (74.1%) 1138 (14.8%)
All respondents 226 (2.8%) 237 (3.0%) 507 (6.3%) 5847 (73.2%) 1176 (14.7%)
12. We also received 4,804 comments in response to this question.
13. Responses to this question reflect many of the themes further explored in later questions. In
particular concerns about the proposal to reduce the rate of high-cost subject funding for the
proposed price group C1.2 subjects (consultation questions two and three) were raised by
more than 50 per cent of respondents. Smaller numbers of respondents also commented on
the effects of our proposals concerning London weighting (questions five and six), targeted
funding allocations (questions 10 to 12) and the effects of our proposals on underrepresented
student groups (questions 13 and 14).
14. The majority of respondents who commented on the proposed reduction to the rate of high-cost
subject funding for price group C1.2 were writing to reflect concerns about how this would
affect art, design and music courses, though a substantial minority were also discussing how
this would affect archaeological courses. A number of common themes were identified in these
responses, including:
a. A general call for the rate of funding to be maintained for price group C1.2 subjects, with
some respondents going further and calling for a general increase in the level of funding
either specifically for price group C1.2 subjects or more generally for all higher education
courses.
b. Support for the principle of protecting the rate of funding for high-cost subjects, but that this
should not be at the expense of introducing cuts to the rate for price group C1.2 subjects. A
respondent noted that:
‘The university welcomes the principle that certain subjects require additional expenditure -
and therefore should be supported appropriately. STEM teaching and research is important
to the UK economy and universities have proved their worth over the course of the
23
pandemic - particularly in medical and health sciences areas. However, we are concerned
that the additional funding proposed comes through de-prioritising other subjects – which
also have an important part to play in the economic and environmental wellbeing of the
country.’
c. Concerns about the effect of such a reduction in funding on the viability of courses in these
subjects. Respondents noted that a restriction in the funding available, even where the
proposed reduction is comparatively small, would have an effect on the affordability of their
provision:
‘this will have a significant impact on those universities with high number of students on C1
subject programmes. With tuition fees fixed, this will further squeeze financial sustainability.
This methodology could discourage universities from offering a wide range of subjects’
‘… [this] is likely to have a detrimental impact, especially on smaller college based higher
education provider[s]’
Respondents also noted that such courses also have recognised high costs of provision,
and that a reduction in the OfS funding available will potentially mean the closure of arts-
based courses, or the need for significantly higher internal cross subsidy to allow such
subjects to remain viable.
‘Any reduction in OfS grant funding in support of these subjects will need to be offset by
reducing expenditure elsewhere. This is likely to have a detrimental impact on the student
body as whole.’
d. Similar concerns expressed the view that the reduction in funding would make such
courses less accessible to certain student groups, particularly those under-represented in
higher education, due to a lack of availability or affordability. Several respondents reflected
a line from the main consultation document that ‘[courses in the creative arts] make a
particularly important contribution to access and participation’, with one also commenting
that:
‘… [reduced OfS funding will give] an advantage to the students who can afford to buy extra
materials and equipment that others from lower socio-economic backgrounds may not be
able to do. This would mean students who have dependents, are carers, or have to take on
extra jobs to afford rent, could not cover the extra course costs.’
e. The view, expressed by the majority of respondents, that the proposals in a wider sense do
not reflect the value of price group C1.2 courses (particularly arts courses) to society. This
was expressed in general terms: ‘Collectively we have turned to the arts to get us through a
difficult time across the world’. More specific comments reflected on the role that such
subjects have in the economy and in the country’s recovery from the COVID-19 pandemic:
‘… [such courses] are absolutely critical to the successful social and economic recovery of
England post-pandemic. Recent research has shown that the speed of the national
economic recovery is likely to be driven by the growth of microbusinesses in the cultural
and creative industries.’
24
f. That the proposed approach does not support the development of interdisciplinary
approaches, reinforcing a division between sciences and the arts:
‘Splitting, for example, IT from other creative subjects could be detrimental to
interdisciplinary subject innovation that our economy will need in the coming years, and to
the pipeline of graduates to key creative and technology growth sectors.’
15. Expanding on the effects of the proposals to the wider UK, respondents commented on the
value of graduates in these areas to the country and the economy. It was noted:
a. That graduates in these areas, leaving aside their subject of study, develop valuable
transferable skills that benefit the economy, with one respondent noting:
‘… creative subjects develop complex problem-solving skills, critical thinking skills, people
management and collaborative skills and emotional intelligence. All skills currently consider
[sic] in short supply by industry’.
b. The value of archaeology graduates to the wider economy, particularly construction.
Respondents noted that: ‘there is a national shortage of archaeologists due to the huge
increase in major construction projects with field workers being recruited abroad to make up
the deficit.’ One comment also noted that:
‘At least 50 per cent of exiting archaeology undergraduates will need to enter the profession
to feed the current forecast pipeline of work. Actual numbers of archaeology graduates
currently entering the profession are close to 10 per cent of the annual cohort […] currently
90 per cent of professional archaeologists in the UK have at least one undergraduate
qualification in the subject. There is currently no alternative training pipeline for this kind of
expertise on the scale required.’
c. That the creative industries are highly valuable to the UK economy, and that the proposed
changes to funding methods threaten the talent pipeline supplying graduates to the
industry:
‘The Creative Industries account for £112bn GVA [Gross Value Added] to the UK economy
and, according to the 2017 review commissioned by the Government and chaired by Sir
Peter Bazalgette, are forecast to create 1m new jobs by 2030. The sector is larger and
growing more swiftly than UK financial services - and it requires a highly trained workforce.’
‘The creative and cultural sector is relatively highly productive: the average GVA-per-worker
generated in [the] UK is £47,600; in the arts, it is £62,000 (over 30 per cent higher). The
sector returns much more to the Exchequer in tax than it receives through subsidy.’
d. That the message sent by the proposals appears to contradict government policy, noting
that the creative industries were one of the key priority sectors identified for development in
the 2017 industrial strategy and that more recently:
25
‘Build Back Better: Our Plan for Growth (HM Treasury, March 2021) identifies the creative
industries as one of the UK’s particular economic strengths, describing them as “a major
success story for the UK, and a critical driver of innovation and growth”’44
It was also noted that the creative industries are a strength for the country, and that the
proposed cuts might weaken the UK’s world-leading role in these areas, both in higher
education and in the larger economy:
‘UK culture is also one of our biggest assets on a global stage. This was recognised in
DCMS’ 2016 Culture White Paper45 […] The annual Soft Power 30 report shows that the
UK consistently ranks second for the culture sub-index, our highest ranking across all
indices, second only to the US.46 As we move forward independently from the EU with
ambitions to be a “Global Britain”, the strength and diversity of British culture is likely to play
a significant part in establishing our global identity and helping to strengthen international
ties’
16. Beyond comments about the effect of the proposals relating to reduction in high-cost subject
funding, respondents also expressed concerns about the removal of London weighting.
Comments highlighted the additional costs involved with providing higher education in London:
‘… targeted allocations to London rightly acknowledge the higher costs, such as staff salaries
and property costs, that are determined by local market forces and are in the most part outside
of the influence of London institutions.’
17. It was also noted that for certain providers, the removal of London weighting would compound
the effects of other proposals in the consultation: ‘some small and specialist institutions will
financially struggle at a time where student numbers for both home and international students
are still unstable.’
A specialist science provider based in London noted that: ‘the modest monetary increase [due
to the increase in the funding rate for price groups A and B] is more than offset by the proposed
removal of the targeted allocation for students attending courses in London.’
18. A small number of comments referred to the effects on medical, dental, nursing and healthcare
courses. Generally, respondents welcomed the proposals to protect the rates of funding for
these subjects, but noted that for London-based providers, any benefit would be cancelled out
by the removal of London weighting. One respondent noted that, when London weighting was
taken into account, they would see a 5.3 per cent decrease in their OfS funding per FTE.
19. A number of respondents also provided comments on the perceived equitability of the
proposals, and the negative effects they expected to see on access and participation.
Commenters highlighted several areas they described as discriminatory, noting that some
44 See: www.gov.uk/government/publications/build-back-better-our-plan-for-growth.
45 See: www.gov.uk/government/publications/culture-white-paper.
46 See: softpower30.com/.
26
types of provider, particularly smaller and specialist institutions and those based in London,
would be disproportionately affected. One provider noted that:
‘Many FE colleges provide opportunities for HE in cold spots of the country and we would urge
OfS to avoid changes to funding which are likely to damage the interests of students from
these areas and from disadvantaged backgrounds.’
Other respondents repeated concerns relating to the perceived value of the arts, noting that the
proposals ‘create an unnecessary and divisive hierarchy of subjects.’
20. The main consultation document noted the important role that performing arts, creative arts,
media studies and archaeology courses have in contributing to access and participation.
Respondents reflected this in their responses and also noted they expected the proposals
would have a negative effect on targets in these areas, with a reduction in the level of support
for these subjects translating into less opportunity for under-represented student groups to
participate in these areas:
‘[the proposed change to] the high-cost subject funding method is likely to be detrimental when
it comes to offering a diverse mix of subjects. That is likely to impact predominantly on modern
universities like [ours] and that could, in turn, narrow the range of subjects offered to students
from low-participation backgrounds.’
21. The removal of London weighting was also specifically highlighted by respondents as likely to
have a negative effect on access and participation, again reflecting points made in the main
consultation document about the greater proportion of students from black, Asian or minority
ethnic backgrounds. A number of respondents asked if an equality analysis had taken place for
the proposals.
22. A substantial minority of respondents expressed concerns about the methods used to prioritise
subjects into price groups, noting that many of the subjects in price group C1.2 are ‘known to
be high cost to deliver as evidenced through the Transparent Approach to Costing (TRAC)
submission.’ Disparities in the teaching costs of certain subjects were mentioned:
‘mathematics, which has a much lower cost base than the other STEM subjects’ and that the
‘reduction in the funding for programmes in the performing arts and media production may be
politically expedient but that it does not reflect the high-cost delivery of these degree courses.’
Some commenters noted that an approach that reflects government priorities (as opposed to
being driven solely by teaching costs) has both advantages and disadvantages:
‘[The proposal] has the advantage of being responsive (for example to events such as the
pandemic) and quick-footed, but it carries dangers because any definition of “national
priorities” will vary widely between stakeholders as well as over time as circumstances
change.’
23. Several respondents discussed the methods used to prioritise subjects, noting that this
appeared to be less driven by the evidence of relative cost than in previous years. Commenters
expressed the worry that this approach would leave higher education funding open to being
driven by ideological and political considerations, and would be less stable as a result.
27
24. A few comments said that STEM subjects were over-supported and should be cut, but these
commenters did not provide evidence for this view. A similarly small number of comments
suggested that the whole funding model should be reviewed.
25. A number of respondents, both those that agreed and disagreed with the proposals, noted the
effects of the proposals on the unit of resource. Comments appreciated the steps taken to
preserve the rate of funding for high-cost subjects, but had concerns about the longer-term
sustainability of the funding rate, given the context of increasing student numbers, costs and
fixed tuition fees. Such respondents called for a longer commitment to funding levels from the
government, noting:
‘… concern that the funding commitments made here do not match the significant increase
in student numbers on high-cost courses seen in 2020 and likely to continue to 2021 and
beyond. As high-cost subjects are of specific strategic value then we would like to see a
commitment to long-term funding at the required level set per student.’
‘… that this proposal does not fully address the substantial decline in the total unit of
resource per taught students (a combination of tuition fee income and OfS recurrent
funding). Real-term income from tuition fees continues to decrease due to the fact that
regulated tuition fees have not been increasing in line with inflation […] costs of our
teaching delivery remain considerably higher than the income and the continuing
deterioration of the unit of resource results in the widening of the gap, which requires cross-
funding from other sources. We expect the situation to worsen even further as a result of
the unplanned increase in the fundable students on undergraduate courses due to atypical
Level 3 examination results in 2020’.
Other respondents, particularly those that disagreed with question 1, called for reductions to
the rate of funding to be addressed through a general increase to the funding available to the
OfS.
26. The final set of themes discussed by respondents looked at the implementation of the
proposed changes. Several respondents noted the short notice that providers have for the
implementation of these changes:
‘… [it is noted] that allocations are unlikely to be announced until June or July 2021 – just
weeks from the start of the academic year leaving very little time for providers to plan for or
adjust to changes. This is especially acute as so many providers have lost other income
generating streams as a result of Covid and are therefore unable to cover sudden losses
from elsewhere.’
‘We are also concerned about the potential CMA [Competition and Markets Authority]
issues over what has already been promised to students for next academic year. Such
severe cuts will undoubtedly impact on some providers' delivery […] and these changes will
negatively impact the student experience. We therefore believe as a matter of principle any
cuts of this nature need at least 12-18 months of lead time so as not to prejudice the
student experience.’
27. A number of respondents also extended calls for the OfS to put in place measures to mitigate
the impact of the changes:
28
‘OfS are asked to consider the impact on individual providers and to set a percentage cap
on the level of grant funding loss any one provider might face in any one year in order to
safeguard and protect the experience of continuing students.’
OfS response and decisions
28. Question 1 specifically concerned the balance of funding between high-cost subject funding
and other elements of grant, whereas question 2 sought views on the prioritisation within
the high-cost subject funding method of certain subjects (and in particular the proposed
reduction to rates of grant for performing and creative arts, media studies and archaeology).
Given that responses to question 1 overlap to a substantial degree with themes raised under
other questions in this consultation, we will not respond here to all the points raised above.
Instead they will be covered under their respective sections below.
29. While we acknowledge the concern in the large majority of responses about cuts to funding
for particular areas, respondents did not, on the whole, suggest alternative approaches to
how our fixed budget should be distributed in a way that would strike a balance between
different priorities.
30. A number of responses to question 1 touched on areas that fall outside the scope of our
consultation. The need for an overall increase in the funding available to us from
government, for example, (see paragraph 25) is for the government, rather than the OfS, to
determine. We have shared all responses, as well as our summary analysis of them, with
the Department for Education.
31. The terms and conditions that the Secretary of State has applied to OfS grant for 2021-22
mean that we must implement the reduction to the rate of high-cost subject funding for the
performing and creative arts and media studies and also remove London weighting. The
terms and conditions also preclude us, without written agreement from the Department for
Education, from mitigating the impact on providers of such reductions through other grants,
which would include phasing in change over a longer period. These requirements release
funding available for other grants and activities. We have considered carefully the responses
to our consultation, and had regard to our duties, the overall funding settlement available to
us and the terms and conditions that apply to it. We continue to believe that it is right to
protect, and if possible enhance, the rate of grant per FTE provided through the main high-
cost subject funding method and the nursing, midwifery and allied health supplement,
particularly where these support science, technology, engineering and mathematics (STEM)
subjects and healthcare disciplines. We have therefore decided to set the budget for high-
cost subject funding at £755 million for academic year 2021-22. This is sufficient to provide
an increase to the rate of grant for subjects in price groups A and B and for courses in
computing and IT, archaeology and pre-registration nursing of 4 per cent compared with
2020-21. These rates remain 1.5 per cent lower in cash terms than for 2019-20.
29
Question 2: To what extent do you agree with the proposal to split price group C1 in order to implement a reduction of 50 per cent to the high-cost subject funding allocated to subjects in the performing arts; creative arts; media studies and archaeology?
32. Table A3 summarises the extent to which respondents to the consultation agreed or disagreed
with the proposal, or neither.
Table A3: Numerical summary of responses to question 2
Respondent type Strongly agree
Tend to agree
Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
4 (3.3%) 27 (22.3%) 23 (19.0%) 61 (50.4%) 6 (5.0%)
On behalf of other organisation
3 (1.8%) 3 (1.8%) 5 (3.0%) 146 (86.4%) 12 (7.1%)
As an individual 131 (1.7%) 31 (0.4%) 56 (0.7%) 7371 (95.8%) 102 (1.3%)
All respondents 138 (1.7%) 61 (0.8%) 84 (1.1%) 7578 (95.0%) 120 (1.5%)
33. We also received 5,946 comments in response to this question.
34. Most comments were against the proposed changes, but a small number were reluctantly in
favour of the change proposed. These respondents recognised that the limited resources
available meant that prioritisation was required and that this would cause reductions in funding
for some subjects.
‘It is difficult to support any reduction in high-cost subject funding. The actual funding per
student FTE here is already modest. However, given the total funding available and the
significant increase in student numbers particularly in higher cost subjects […], the proposal
is understandable to try to protect the rate of grant per student FTE in higher cost subjects.’
‘However, in line with our first response, we broadly agree that it makes sense to more
generously fund the costliest programmes. In particular, the technical document which
accompanies this consultation [and] models funding impacts for providers based on their
region notes that all areas outside of London, on average, are net beneficiaries of this new
hypothecation.’
‘Whilst we would prefer to see high-cost funding for performing arts, creative arts, media
and archaeology maintained at the current level, we consider the splitting of the C1 group
into C1.1 and C1.2 to be a logical way to enact the priorities set out in the Secretary of
State’s annual grant letter.’
In these cases, the proposed split was seen as being the most equitable or least
disadvantageous way of making the required changes. Some respondents felt that, although
the strategy was correct, the reduction of 50 per cent was excessive. A very small number of
respondents felt that funding for the subjects affected was already excessive.
30
35. A large number of themes were evident in the responses against the proposed change,
summarised in the paragraphs below. A very large proportion of the comments made were
specifically addressing reductions in funding for performing and creative arts and music
courses, though a minority of other subjects such as archaeology and media studies were
referenced.
36. Concerns were expressed about the sustainability of provision of C1.2 subjects. Although this
concern was noted at all levels, a number of respondents highlighted concerns for small
providers in general and further education and sixth form colleges in particular. Respondents
also noted that the proposals would interact with the expected ‘demographic bulge’ in student
numbers to reduce student choice. Some suggested that this would have a longer-term effect
on the provision of these subjects in schools, particularly with regard to the teaching of music, a
subject in which the government has recently made announcements about changes in the
school curriculum. Some suggested that if a cut in the funding rate for price group C1.2
subjects was necessary, it should be less than 50 per cent.
‘We believe that rather than seeking to reduce the funding to institutions as proposed,
which could result in some courses becoming financially unviable and being forced to
reduce the quality of their provision or even close, the Government should maintain the
current level of funding in order to ensure that arts education continues to be available to
and accessible by all those with the potential to succeed.’
‘While [the respondent] understands the need for the OfS to prioritise its funding in line with
government priorities, we are gravely concerned the proposed changes create a vast
funding gap for universities who deliver significant levels of provision for subjects in price
group C1.2, with implications for financial sustainability of those hardest hit.’
‘Today’s undergraduates in creative disciplines are tomorrow’s art, music and performing
arts teachers and youth arts professionals. Funding provision to maintain a broad provision
of courses at HE level is critical to the future of arts and creative disciplines in schools and
for young people in informal settings outside school’
37. One respondent voiced concern that the negative effect of the proposed changes would be
amplified if their capital grant bid was unsuccessful (referring to our separate consultation on
capital funding for 2021-22, which proposed bidding as a capital funding method for 2021-22).
Another highlighted the potential difficulties for new and poorer providers in contrast to
established providers with financial reserves.
38. Another common theme discussed was the concern that the division of C1 subjects into two
groups created a false dichotomy between ‘the arts’ and ‘STEM subjects’ in which the former is
seen as less valuable to society than the latter.
‘I am deeply also concerned that this proposal for prioritising funding for STEM subjects, is
based on a differentiation between “C1.2” and other high costs subjects, that consolidates a
false boundary between “STEM” and creative arts, media, performance and humanities
subjects.’
Some suggested that it was better to think of ‘STEAM’ subjects (science, technology,
engineering, arts and mathematics) rather than STEM.
31
39. A very small number of respondents speculated on the potential use of student number
controls as a means of controlling expenditure, in preference to reducing the rate of funding
provided for subjects in price group C1.2.
40. Many respondents noted the proposed changes would have a negative effect on the
accessibility of higher education courses, particularly when looking at students from
underrepresented and ‘non-traditional’ groups (e.g. students who are the first in their family to
participate in higher education), disabled students, and students with mental health issues.
More generally, respondents referred to concerns about the effect on the sector’s widening
participation agenda as a whole.
‘We are concerned that the current proposals, which we believe will result in fewer arts
courses being offered, will limit rather than expand opportunity for all, widen existing
inequalities and decrease participation rates in higher education by students with
disabilities and those from lower socio-economic groups.’
‘EDI [equality, diversity and inclusion] matters – it’s noted that these subjects have a higher
proportion of students with a disability, low POLAR etc47 – and cutting the funding will
impact on these groups first at a time when we should be broadening this even further. In
particular the concern will be that Music Departments with a more local reach will disappear
and with that the opportunities for young people in their immediate area’.
‘Your own report (paragraphs 22-23) makes it clear that the subsidising [of] subjects in
group C1.2 has direct benefits for widening participation, access and diversity; and that
these courses feed into shortage occupations. The proposal is therefore to maintain funding
for “priority” courses at the expense of opportunities for students from diverse and less
privileged backgrounds, a clear contradiction to the government's aim of “levelling up”’.
‘… it is important to recognise that not all students can or wish to leave home in order to
study. If courses in these subjects become the preserve of a few institutions it will lead to
geographical cold spots which will seriously disadvantage students in many parts of the
country – particularly those with caring responsibilities or specific needs which means they
wish to study locally. Small and specialist institutions have an important role to play but this
should not be at the expense of the wider sector.’
41. It was noted that the proposals would have an adverse effect on students’ future opportunities
and aspirations and that their needs and quality of choice and experience would be diminished.
‘Fewer arts courses will also limit the supply of high-quality arts teachers at a time when
every year for the last five, barring 2020, the Department for Education Teacher Supply
Model recruitment targets have not been met for Art & Design, Drama and Music teacher
training.’
42. Respondents also noted specific financial consequences for students in these subjects,
particularly those taking arts subjects.
47 POLAR is the participation of local areas. See: www.officeforstudents.org.uk/data-and-analysis/young-
participation-by-area/about-polar-and-adult-he/.
32
‘As it already stands, the arts are hugely underfunded. From my personal experience as a
fine art student, I have spent over £1000 towards my degree on materials to create my
work. This includes basic materials i.e. charcoal and paper. As well as my fine art materials,
I have had to pay for many books for my written modules. This is extremely unfair as, for
instance, my housemate who studies natural science is given ALL of her textbooks for free
and does not have to pay for materials or solutions when she conducts chemical
experiments in the labs.’
‘Students of subjects in the performing arts; creative arts; media studies and archaeology
have taken a big financial hit during the pandemic due to lack of materials provision and
lack of access to expensive specialised studio and workshop space, which were already
lacking beforehand due to tight university budgets. Students had to crowdfund projects or
share cramped, unsafe spaces to carry out their practice, which put undue stress on them.’
43. Similar concerns were expressed about the long-term impact of the proposed changes on
regional and national economies and the broader skillset available to the workforce. A large
number of respondents noted the value of the contribution that the larger arts sector makes to
the UK economy:
‘… in 2018 the UK music industry contributed £5.2 billion to the UK economy […] while the
DCMS's [Department for Digital, Culture, Media and Sport] own figures demonstrate that in
the same year the arts as a whole made an economic contribution of over £32 billion.’
44. Other comments in this area discussed similar effects that they expected to result for specific
areas, relating to the loss of local provision in these subjects. Again, this was most frequently
discussed in relation to the arts sector.
‘We are concerned that these proposed changes will irrevocably damage the ecology of the
West Midlands cultural sector, its economic, social and cultural value and ultimately result
in further “drains” on talent leaving the region, in turn devaluing the region’s cultural life and
prospects. This is in direct contrast to the government’s “levelling up” agenda.’
‘The creative industries are a motor of growth in local economies across the UK, not just in
London and the South East of England. […] There has also been an explosion of creative
entrepreneurship: almost nine in ten local economies grew their creative business
population over this period, and 83 per cent of these areas grew this creative
entrepreneurial community faster than other sectors […] HEIs that deliver creative courses
are essential to driving such local growth because they: attract, cultivate and retain a
diverse pipeline of vital skilled workers and creative entrepreneurs to their region; attract
creative businesses to base their business activities nearby; invest in local infrastructure
and institutions, enabling creative ecosystems and clusters to regenerate and thrive; invest
in local R&D and innovation, enabling their local economies to become world-leading;
strengthen connections between the creative sector and other industries, further unlocking
a region’s ability to innovate and grow; unlock creative solutions to local civic, social and
economic challenges, ranging from sustainability through to the re-purposing of public
space.’
‘The subjects targeted all provide major contributions and the workers who create the
possibility of the cultural and creative industries. The Department of Digital, Culture, Media
33
and Sport reported that in 2019 that creative and cultural industries contributed 7.7 per cent
of total UK gross value added (or contribution to GDP) 2019. (DCMS2020) These estimates
place cultural and creative industries as broadly equivalent to the construction industries,
two and a half times the size of the automobile industries and 10 times the size of
agriculture. These proposals undermine and place at risk this essential economic sector.’
45. Many responses noted the potential adverse effect of the proposed reductions on the
performance of the UK economy; some also noted the resulting adverse impact on tax
revenues. Several evidenced this by referring to recent statistics suggesting that economic
growth in the arts outperformed that of other sectors several fold; many noted that this
appeared to contradict government policy as recently expressed in the concepts of ‘levelling
up’, ‘Build Back Better’, the ‘growth agenda’ and the recently announced music curriculum for
schools.
‘Creative roles now make up 30 per cent of the Government’s Shortage Occupation List
(SOL), and include many of the jobs cited as being very likely to grow as a share of the
workforce by 2030, by virtue of being resistant to automation. These proposals risk
worsening current skills shortages. With the likely closure of existing arts courses and
Departments across the UK, existing skills shortages would be negatively affected, and
new skills shortages would undoubtedly emerge. We recognise these skills shortages as a
major long-term strategic challenge that will impact our capacity for growth and innovation.’
‘This value was recognised in government’s former Industrial Strategy and recent “Plan for
Growth”, published alongside the Spring Budget, where the creative industries were
highlighted as a priority sector.’
46. Respondents also expressed the view that the proposals might result in a diminishing of the
UK’s standing and international reputation in these subjects, both in terms of higher education
and in the broader sectors affected.
‘The UK’s HE music provision could lose its world-leading status as a result of this cut’.
A few responses suggested that the proposals would discourage foreign students from coming
to study in the UK or that providers may have difficulty in attracting such students. It was also
suggested that there would be an adverse effect on the UK’s ‘soft power’ and global image,
potentially having a deleterious effect on tourism and the economy, as well eroding the
country’s own self-image.
‘The proposal would undermine Britain’s world lead in “soft power”. Britain’s ability to
influence world-wide through our culture thinking about the nature of the world will be
damaged. This would severely hamper a global Britain by damaging one area, in music,
media, performance and so on, in which Britain is both clearly world leading and which
projects British creativity and values.’
‘The government’s plan for growth highlights that the digital and creative industry sectors
are a major success story for the UK, and a critical driver of innovation and growth. Cutting
the pipeline of talent will have serious repercussions for the UK’s long-term international
competitiveness.’
34
47. Some respondents commented that price group C1.2 subjects, particularly archaeology, were
also identified by the government as being skills in short supply and suggested that this was
likely to have a detrimental effect on the ability to advance many of the government’s strategic
aims.
‘Archaeology is a recognised construction skill and a necessary part of the supply chain for
the delivery of housing and infrastructure development, for instance HS2, Crossrail, and the
A14 corridor project. Archaeology is essential to meet planning policy requirements and is
therefore a contributor to key national priorities […] These skills are, in addition, recognised
by Government as being subject to a shortage, with archaeology jobs currently listed on the
UK Shortage Occupation List.’
‘For 150 years the UK has been at the cutting edge of international archaeology, and we
still have the four top-ranked universities for archaeology in the world according to the QS
rankings.48 However, this position has been seriously eroded by the increasing withdrawal
of funding from the subject over the last 10 to 15 years, with many university departments
dramatically contracting […]. Already there are virtually no British graduate students in
archaeology because there is no funding for them; our universities overwhelming[ly] teach
overseas grad students. In another 10 years there'll be almost no British archaeologists in
academia. Foreign academics will teach foreign students in UK universities.’
48. Many responses highlighted the concept that the study of creative subjects promoted personal
growth, resilience, mental health and wellbeing and that they also played a role in local
communities, adding diversity and cohesion. Any reduction of funding would have an impact on
these benefits. One respondent said:
‘Being a recent graduate from a performance-based undergrad and master's degree […]
I cannot express how valuable the skills are that I gained on both programs. I now work for
the university […] and the creativity, initiative, confidence and endless personable skills are
needed every day to thrive in my role and properly support the students I work with.’
49. Many of the subject areas affected had increasing inter-disciplinary crossover with more
‘technical’ subjects, particularly digital and health related subjects. In addition, several
respondents suggested that the kind of learning and soft skills nurtured by studying the arts
and humanities equipped graduates with the ability to quickly adapt to new environments and
to bring their skills and creativity to their work. Some argued that this capability would be
required in jobs that had not yet been imagined or created:
‘Arts graduates contribute across disciplines in their working lives, not just in theatres and
concert halls. They work in prisons, hospitals, offices, schools, gaining other qualifications
and helping others to find their own voice in the world. These subjects do not narrow
students' outlook or employability – they help students to see the world as it is, developing
transferable, lateral skills, and they are incredibly employable, something borne out in data
from many student destination studies, where the number of students in employment does
not significantly differ from any other discipline.’
48 See: https://www.topuniversities.com/university-rankings/university-subject-rankings/2021/archaeology.
35
50. Some responses suggested that the proposed policy seemed not to recognise the nature of the
subjects affected, the role that they played in the fabric of national life and the intangible nature
of their value to the country, its economy and people.
‘Music and the arts are of huge significance to the nation's quality of life and wellbeing. This
was clearly demonstrated during lockdown when millions turned to music as a way to cope,
relax, escape, raise their mood or keep them company. Covid revealed the central
importance of music in people’s lives, yet these cuts show a complete lack of
understanding of the role music plays in society.’
51. A substantial number of respondents commented on the basis on which the decisions to make
reductions were being made:
a. Some respondents discussed the basis for classification of certain subjects as ‘strategic’
and ‘lower priority’. Comments received disputed the basis for assigning a lower strategic
priority to subjects placed in price group C1.2, reflecting points noted above about their
value.
‘The notion of strategic priority starts with a highly limited concept of the value that accrues
from the experience of higher education. It is highly problematic to associate the value of a
subject with the earnings of graduates, as it assumes that the purpose of higher education
is to contribute to GDP, and provide training for employment, rather than to improve the
quality of life more generally in the UK and beyond.’
b. Respondents also perceived contradictions between assigning a ‘lower’ priority to these
subjects, given the value placed on them in government priorities, and in the role that they
play in access and participation efforts.
‘The narrative around performing arts, creative arts, media studies and archaeology as
being “less importantly strategic” subjects contradicts the statements and
acknowledgements made within the [main consultation document] about the benefits and
“huge contribution” they make to society.’
52. Respondents also commented that the proposal meant that the provision of OfS high-cost
subject funding was moving away from a true reflection of the cost of provision, with responses
from registered providers and sector bodies referencing the Transparent Approach to Costing
(TRAC) data to support their argument.
‘High-cost subject funding was established in recognition that costs to teach certain
subjects are higher than can be met through course fees alone. Both the allocation and
weighting of this funding has historically been, at least in part, based on cost centre
expenditure and TRAC T information.49 […] The proposed change represents a move from
this evidenced cost-based approach to one based on a perception of strategic value. This
does not seem a particularly sound basis for the longer term sustainability of the diverse HE
subject base that underpins the full range of UK economic output.’
49 TRAC(T) is the transparent approach to costing for teaching. See: www.trac.ac.uk/about/.
36
‘Our costs in delivering [archaeology] are of a magnitude that demand the current C1
premium. For example, Geographical Information Systems are integral to the teaching of
Archaeology degrees, yet HECoS 100369 (Geographical Information Systems degrees) will
retain its place in band C1. In short, the costs of teaching Archaeology have not dropped
either proportionately or in real terms, and they are directly comparable with other subjects
[such] as Environmental Science which have retained their position in the higher band, and
arguably with degrees in Earth and Environmental sciences which are in band B’.
‘We believe that if price group C1 were to be split, the decision of which subject should end
up in which group should be based on the analysis of costs, as this would be a fairer basis;
the “price” would then relate more closely to actual data as opposed to subjective value
judgements. For example, TRACT T data for our institution shows considerably higher
costs per student in the cost centre 126 “Archaeology” than 121 “IT, systems sciences &
computer software engineering”. It can also be expected that Computer Science
departments across the sector will have greater ability to cross-fund between their various
activities in comparison with performing and creative arts, as they are more likely to attract
research funding from industry at full economic cost or higher and can have other sources
of income through commercialisation, consultancy and IP [intellectual property].’
53. Several responses questioned the nature of the data used to make the decision and the basis
of the classification of subjects in the price group split. Some responses also went further,
suggesting that other factors should be taken into account, such as the costs of delivery for
individual providers and measures of quality of provision, such as graduate outcomes.
‘No consideration has been given to the quality of the course or the track record of the
institution delivering it.’
54. A small number of responses discussed government policy and suggested that the changes
proposed were ideologically or politically driven.
‘The inequity of the proposed changes to the various subject areas is so extreme that it
risks losing the confidence of the sector. Members of our own subject association find it
difficult to understand the proposed cut to the subjects in C1.2 as driven by anything other
than ideology.’
55. A very high proportion of respondents expressed the view that the protection of the rate of
funding for subjects in price groups A, B and C1.1 should not be done at the expense of a
reduction to subjects in price group C1.2. A number of respondents suggested that the
additional funds could be made available by:
a. Utilising the London weighting allocations.
‘We have some concerns about the proposed discontinuation of the London
weighting […] but we note that the £64 million freed up by ending it would be more
than enough to meet the cost of increasing FTE numbers in all of price groups A, B,
and C1 (i.e. both C1.1 and C1.2), and without reducing the funding per FTE in any
of them.’
37
b. Utilising the allocations for very high-cost STEM subjects.
‘[The provider] proposes there is no reduction with the 2020-21 allocation of £36m
maintained in cash terms. The cost of retaining the budget at £36m will be achieved
by removing the budget for very high-cost subjects (£24m)’.
c. Small providers whose provision was largely in the affected subjects should be
treated differently to courses offered within larger, multi-disciplinary providers, in
order to mitigate any disproportionate effects of the reduction in funding.
‘The nature of performing arts tuition in a small specialist institution differs greatly to
that in a larger institution. The conservatory delivery model is focussed on intensive
1:1 and small group teaching plus performance activity which inherently is more
costly and resource intensive. The approach should differ through moving students
in category C1 at small specialist institutions into C1.1, rather than C1.2. The impact
of this change would be relatively modest compared to the changes being proposed
overall, and also would support the stated priority of protecting the rate of grant per
FTE for high cost subjects.’
d. Tailoring allocations on a provider-by-provider basis:
‘My suggestion would be, if arts funding has to be cut at all (which is a big if, and
certainly not an inevitability), it needs to be tailored to individual institutions to make
sure that they can remain afloat through other income until the post-Brexit and post-
Covid "new normal" is established.’
56. A quarter of respondents commented on the short notice given to providers on the proposed
changes, and that this did not allow providers much time to implement these changes and put
in place measures to mitigate their impact.
‘We would also add that there may well be CMA [Competition and Markets Authority]
concerns over what has been promised to students in their contracts – these proposed
funding cuts will necessarily reduce the ability of a large number of providers to deliver what
has been promised during the recruitment process, which will result in consumer protection
concerns and should be seen as extremely unfair and prejudicial to students. Any cuts of
this nature need at least 12 to 18 months of lead time so as not to prejudice the student
experience and breach consumer law.’
‘The proposed approach does not seem to take into account the medium and long-term
implications and the potential unintended consequences. Universities are required to have
a long-term view and manage their investments and financial plans to maximise value for
money. The proposed change and the short notice make it very difficult to manage long
term investments and universities will have to consider its ongoing and future investments
in the proposed C1.2 subjects.’
‘Although the proposal to split the price group C1 seems sensible a reduction of 50 per cent
does seem severe with only a few months before this is implemented. As stated in the
consultation many of these courses are expensive for providers to offer. Due to the change
in process this year the fact that 2021-22 proposed allocations have only just been released
it will be difficult for universities to reduce their cost base in this short period or be able to
38
absorb the reduction in income. By not increasing the rate and reallocating the increase in
rate for both A, B subjects the funds would be available to reduce C1.2 subjects to 75 per
cent.’
57. Respondents also called for a phased implementation to the changes or for measures to
mitigate the effects of the changes on the most affected providers.
‘Should the decision be made to pursue these cuts, then at least a phased reduction over
time would allow for Covid recovery and will be more equitable and enable HEPs [Higher
Education Providers] to look for other sources of funding to continue the support to access
and participation in these subjects.’
58. Some respondents commented on the interaction of the proposed changes to price groups and
to the specialist institutions targeted allocation. It was noted that these may have an
unintended effect of concentrating arts provision at specialist providers, with a deleterious
effect at other institutions.
‘Importantly, by focusing on “specialist providers” the proposal ignores the exceptional
teaching and research being conducted across the HE landscape in the UK and as a
consequence ensures only the wealthiest and most privileged will be able to access these
subjects.’
59. It was noted that not increasing the targeted allocation for specialist institutions could free up
money to mitigate the effects of any reduction in funding for price group C1.2:
‘The proposal here contradicts the later proposal to increase funding for specialist
providers, many of whom will be offering provision in these subject areas. Choosing not to
increase funding to a few, specialist providers would release £10m in funding which would
halve the loss of funding to performing arts; creative arts; media studies and archaeology
across the sector.’
‘However, it should be noted that the savings that will be realised by cutting these band C
subjects by 50 per cent could easily be made by reducing the amount of funding that is
allocated to a small and arbitrary list of providers, already well funded, that have not been
assessed under relevant methodology to be worthy of this significant pot of specialist
funding. So, cutting that specialist funding by say 50 per cent and holding current funding
levels of all band C subjects would seem a much fairer and more sensible approach to
achieving the Secretary of State’s aims while protecting the large number of smaller arts-
based providers who depend on this funding.’
60. Around a quarter of responses (mainly those that utilised the text of template responses such
as the one referred to above from the Musicians’ Union) expressed concern that the proposals
(and the Secretary of State’s guidance on which they are based) did not have regard to the
OfS’s statutory duties, particularly those regarding promoting student choice:
‘We are concerned that the proposal does not have sufficient regard to the OfS’ duties, as
enshrined in the Higher Education and Research Act 2017, to promote “greater choice and
opportunities for students” and “equality of opportunity in connection with access to and
participation in higher education”. We are concerned that it will result in fewer arts courses
being offered by HE providers, and subsequently fewer opportunities for participation in
39
these areas. We are concerned that it will reduce diversity and opportunity in creative
training and work, and in our creative industries for which these courses provide high-
quality training and an important talent pipeline.’
Some responses suggested that the OfS should contest the Secretary of State’s guidance on
the grounds that it is not in line with our statutory duties.
61. A very small number of responses suggested that the proposals may be ‘discriminatory’ on
these grounds:
a. The content of the main consultation document’s paragraphs 22a and 22b, which describe
the contribution that design, creative and performing arts, media, journalism and
communications courses make to access and participation efforts.
b. The exclusion of music therapy, art therapy and drama therapy from the list of subjects
defined as allied health professions, both in terms of inclusion in price group C1.1 and in
terms of qualifying for the nursing, midwifery and allied health supplement.
‘This proposal claims to wish to distribute funds in order to better support the Allied
Health Professions [AHP]. Yet Music Therapy, Art Therapy and Drama Therapy are
all Allied Health Professions, and this proposal would dramatically reduce core
training for these AHP courses. This is discriminatory, and if the OfS does genuinely
wish to support the Allied Health Professions it should be supporting all AHP
students to be able to access fundamental training.’
c. The effect of the proposed changes on those with disabilities.
62. As well as commenting on the equity of the proposed changes, a small number of respondents
expressed concerns that the proposals would be followed by similar reductions in future years.
63. A small number of respondents highlighted the potential negative effect of the proposed
changes on staff at providers (both academic and others) and those working for other
employers either in partnership with or in some way dependent on providers.
OfS response and decisions
64. We have noted the arguments presented by many respondents relating to the sustainability
of subjects in the performing and creative arts, media studies and archaeology; the
contribution they make to the economy and society and the soft power they bring to the UK’s
influence internationally; the relationship with other aspects of government policy (such as
its shortage occupation list and ‘Build Back Better’); and the skills and benefits they bring to
the individuals who study them.
65. The terms and conditions that the Secretary of State has applied to OfS grant for 2021-22
mean that we must implement the reduction to the rate of high-cost subject funding for the
performing and creative arts and media studies (the terms and conditions no longer require
the reduction to apply to archaeology). If we do not, we may be required to repay the whole
or any part of the grant still held by us to the Department of Education. The terms and
conditions also preclude us, without written agreement from the Department for Education,
40
from mitigating the impact on providers of such reductions through other grants, which
would include phasing in change over a longer period. We are also required under terms
and conditions applied by the Secretary of State, to implement the removal of London
weighting in our allocations and to increase by £10 million the separate funding allocation
provided to world-leading specialist providers.
66. For this reason, we confirm that for academic year 2021-22 we will split price group C1 into
C1.1 (covering computing and IT, archaeology and pre-registration courses in nursing) and
C1.2 (covering performing and creative arts and media studies). Activity in price group C1.2
will be subject to a reduction of 50 per cent (£121.50) in the high-cost subject funding rate of
grant per FTE compared with academic year 2020-21.
67. Paragraphs 27 and 28 and Annex B of our consultation in OfS 2021.01 explained how
student activity is assigned to price groups for our funding purposes. For some courses, this
is based on the fact that the course leads to qualification to practice in certain professions or
provides further professional development for those already so qualified. For others, it is
based on the subject codes that apply to the courses, reflecting their subject content. It is
subject codes that determine how any activity might be assigned to the new price group
C1.2. Any particular course may have more than one subject code and in this situation the
student activity on the course would be split between price groups according to those
different subject codes. In this respect, there can be an important distinction between
funding for courses and funding for subjects.
68. The assignment of subjects to price group C as a whole, and price group C1 within it,
already reflects that such subjects have a laboratory, studio or field work element that gives
rise to higher cost. A number of respondents argued against the proposed reduction to
funding for archaeology on the basis of the science content of archaeology courses.
However, where there is such science content, and this is reflected in course subject codes,
then a proportion of activity on the course will be assigned to price group B and funded at a
higher rate. Specifically, using the subject codes that apply to providers that submit data
returns to the Higher Education Statistics Agency (HESA), subject codes that come under
the Common Aggregation Hierarchy (CAH) for Archaeology (CAH20-01-03) are mapped to
price group C1, whereas subjects within Forensic and Archaeological Sciences (CAH07-04-
02) are assigned to price group B. The latter CAH code includes the Higher Education
Classification of Subjects (HECoS) codes for Archaeological Sciences (HECoS 100384) and
Forensic Archaeology (HECoS 101219).50
69. We do not accept arguments about the reduction for C1.2 subjects threatening
interdisciplinarity across the arts, science and engineering (see paragraph 14.f of this
annex). Where courses contain content across different subject areas, that may be reflected
in the subject codes used, and therefore the rates of grant provided. Although mathematics
is a STEM subject (see paragraph 2422 of this annex), it is assigned to price group C2, and
therefore does not attract high-cost subject funding.
50 See Table B1 and footnote 89 in Annex B of OfS 2021.01:
www.officeforstudents.org.uk/publications/consultation-on-recurrent-funding-for-2021-22/.
41
70. We also do not accept arguments about the treatment of courses in art therapy, music
therapy and drama therapy. Some pre-registration courses for allied health professions were
previously funded by the Department of Health and Social Care (DHSC). Because of this,
finance and student FTEs for such courses were not included in the TRAC(T) returns
submitted by providers and this meant that we (and our predecessor body, the Higher
Education Funding Council for England, HEFCE) did not have data on the cost of such
courses. HEFCE therefore commissioned costing studies to inform how these courses
should be treated once funding responsibility for them transferred from the DHSC.51 These
costing studies informed how such courses should be assigned to price groups and also led
to the introduction of the nursing, midwifery and allied health supplement, which recognises
where costs exceed what would otherwise be met through course fees and other OfS
grants.
71. While art therapy, music therapy and drama therapy are indeed allied health professions,
pre-registration courses in these disciplines were not among those previously funded by the
DHSC or included in the HEFCE costing studies. Rather, they were included in the TRAC(T)
data submitted by providers, which informed the assignment of activity to price groups and
the rates of grant that have applied to them. We do not have evidence about how the costs
of these courses compare with other allied health professions that were included in the
HEFCE costing studies and we do not accept that there are grounds for taking a different
approach to them compared with other courses that have been covered by TRAC(T) data.
The latter includes other healthcare courses such as pre- and post-registration courses in
medicine and dentistry, as well as post-registration courses in nursing, midwifery and allied
health professions.
72. A number of respondents argued that certain proposals in our consultation were in conflict
with our duties under section 2 of HERA. Respondents referred to the OfS’s duties ‘to
promote greater choice and opportunity for students’ or ‘to promote equality of opportunity’
This does not correctly reflect the OfS’s duties. Section 2(1) imposes a duty to have regard
to the various matters specified in sub-paragraphs (a)-(g). It is well-established that this
statutory formulation does not require a public authority to achieve those matters. To the
extent that respondents suggest that s.2(1) imposed on the OfS (for example) a statutory
duty of promoting greater choice and opportunity, they are wrong.
73. Terms and conditions issued under section 74 of HERA impose a statutory obligation on the
OfS to distribute funding in a particular way. Therefore, while we have had regard to all
relevant statutory duties in developing our proposals, we ultimately had to fully comply with
the terms and conditions of funding imposed by the Secretary of State in arriving at the
decisions set out in this document.
74. We recognise that students studying subjects in price group C1.2 may have additional
course-related costs beyond the course fee, such as for art materials or musical
instruments.52 Respondents expressed concern that such charges might increase as
51 See: webarchive.nationalarchives.gov.uk/20180405125423/http://www.hefce.ac.uk/lt/healthcare/nursing/.
52 Previous regulations set out in statutory instrument 1999/2265
(https://www.legislation.gov.uk/uksi/1999/2265/made) and guidance on them published in June 1999 by the
former Department for Education and Skills (available from:
42
providers sought to offset the reduced income for courses in price group C1.2 and that this
could have an adverse effect on student diversity, particularly in relation to those from
disadvantaged backgrounds. We expect providers to manage such risks through the support
they give to students facing hardship. Providers have scope within the overall resources
available to them (including both course fees and OfS student premium funding) to target
support to those most in need, particularly where this will support students’ continuation of
study and successful outcomes.
Question 3: Notwithstanding your answer to question 2, if we were to split price group C1 as proposed, to what extent do you agree with our approach to implementing this?
75. Table A4 summarises the extent to which respondents to the consultation agreed or disagreed
with the proposal, or neither.
Table A4: Numerical summary of responses to question 3
Respondent type Strongly agree
Tend to agree
Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
9 (7.5%) 52 (43.3%) 13 (10.8%) 30 (25.0%) 16 (13.3%)
On behalf of other organisation
2 (1.2%) 6 (3.6%) 10 (6.0%) 111 (66.1%) 39 (23.2%)
As an individual 109 (1.4%) 82 (1.1%) 316 (4.2%) 5895 (78.1%) 1150 (15.2%)
All respondents 120 (1.5%) 140 (1.8%) 339 (4.3%) 6036 (77.0%) 1205 (15.4%)
76. We also received 4,051 comments in response to this question, with a substantial majority of
these reiterating themes raised in question 2 or refusing to engage with the premise of
question 3.
‘We disagree with the premise of splitting this category. It has not been proven that the
costs of delivering these courses has fallen. Unless this is the case, the categories should
not be changed.’
Only a small minority of respondents commented directly on issues to do with the proposed
implementation of a split in price groups.
77. Of the 90 comments made by those responding on behalf of a provider, 44 expressed support
for the proposed implementation methods, though in some cases this support was reluctant
and qualified.
webarchive.nationalarchives.gov.uk/20021028043155/http://www.dfes.gov.uk:80/studentsupport/administrat
ors/dsp_section_18.shtml) have allowed for charges in addition to course fees relating to goods that become
the property of the student. Those regulations therefore would permit charges for art materials, where the art
becomes the property of the student, but would not permit charges for, for example, chemicals used in
teaching chemistry.
43
‘It seems a logical and fair way to classify subjects.’
‘The use of LDCS [Learn Direct Classification System] and HECoS subject codes is broadly
appropriate for this purpose […] as noted, we would still prefer C1 not to be split nor its
funding rate reduced.’
‘This seems the least damaging given there is only extremely limited additional funding
being provided to support the very high cost subjects.’
78. Some respondents reiterated calls for the reduction to the rate of funding for price group C1.2
subjects to be reassessed, with a smaller reduction put in place; a reduction of 30 per cent in
2021-22 and a further reduction of 20 per cent in 2022-23 was suggested.
‘If the OfS goes ahead […] then we agree that those subjects that will lose the full allocation
should still be given some funding. This is for two reasons. Firstly, there would be a
substantial financial shortfall if providers who were not expecting this change to suddenly
receive nothing, and secondly whilst it is not the full amount, the money does still take
account of the fact that these are strategically important subjects to the economy and are
more expensive to deliver.’
79. This theme was often paired with concerns about the timing of the implementation of the
proposed changes. Respondents noted that providers would have very little time to be able to
adjust to the proposed reductions in their funding and called for mitigation to be put in place.
‘While clearly we welcome that the reduction in funding is to be staggered over two years,
for some departments the high-cost funding is a significant part of their operating budget
and the immediate reduction will be difficult to manage operationally and could have an
adverse effect on their ability to deliver as normal and therefore there is a possible knock-
on effect to the experience of students on those courses. We would prefer a deferral of cuts
by a year or two to allow time for long-term operating budgets to be amended and a more
phased reduction in funding to allow for the development of alternative streams.’
‘We would prefer to see a phased reduction over two to three years to enable planning and
avoid consumer protection issues, rather than an immediate 50 per cent reduction to C1.2
in the interest of fairness to students and the recognition that they are relevant to
professions in the government’s shortage occupation list.’
80. Comments made on the methodology used to identify the subjects falling into price groups
C1.1 and C1.2 fell into a number of themes. A number of responses approved of the use of
LDCS and HECoS codes, noting that they felt this was the best tool for the job.
81. A small number of respondents appear to have misinterpreted the consultation as saying that
subjects would be assigned to price groups purely on the basis of CAH codes. Such comments
noted that such an approach would not allow for the content of the course to be fully explored:
‘The OfS proposes to primarily use CAH codes to categorise courses into funding groups.
This does not allow for a fully considered analysis of course content and whether a
provider’s course content meets the definition of “strategic priority”.’
44
‘Our proposed approach would be to split C1 by HECoS code not CAH subject code. In
total there are 1093 HECoS codes so we would welcome further consultation on which of
these codes should remain C1 due to the crossover with strategic priority areas for the
government rather than applying a blanket rule at CAH subject code level.’
‘The consultation annex notes that some qualifications contain study in two or more distinct
subject areas, and many students take a combination of creative and art historical subjects
– i.e. Fine Art and History of Art. For certain institutions an interdisciplinary approach is a
key part of their offer and may also include courses featured within other subjects also
suggested as being included within C1.2 (performing arts, media, archaeology). With this in
mind we do not see that there is a benefit in segmenting price group C1 in the manner
suggested within the consultation.’
82. A few respondents noted issues they felt existed with specific HECoS and CAH codes in:
a. Engineering and design:
‘These codings are overly prescriptive and general. CAH25-01-01 & [CAH25-]01-05
embrace areas of postgraduate design engineering and robotics design which the
[provider] believes should be classified as C.1 “Engineering subjects” and UX [user
experience]/Data Visualisation programmes which should be classified as
“Information Technology” and therefore C1.1.’
b. Media studies:
‘As Appendix B makes clear the elastic rubric of “media studies” embraces no fewer
than four CAH categories and six LDCS categories. The many programmes within
these categories vary enormously in the extent to which they provide vocational and
focused professional training, and to which they are rooted in social science,
humanities, or technological forms and bases of teaching […] For all these reasons,
we see the proposed split of the price group as based on superficial labelling rather
than serious consideration of actual and necessary provision.’
c. Archaeology:
‘The current HECoS codings for archaeology are not always helpful as they often
mask the STEM elements to the discipline and therefore fail to reflect the granularity
of archaeology degree content. Identifying the strong science content of some
archaeology degrees would lead to greater clarity for students when choosing their
degree and underpin why archaeology should not be split into the lower price
group.’
d. Library and information science:
‘We strongly disagree with the inclusion of “Librarianship” in the C1 or C1.2
categories […] Library and Information Science most commonly sits alongside
Computer Sciences and Technology in HEIs. Alternatively, it is positioned alongside
programmes in Business and Administration […] [the Chartered Institute of Library
and Information professionals] advises that they have consulted with HEI learning
providers in Library and Information Science, and that they confirm that instruction is
45
very low-cost when compared to other academic disciplines, requiring very little in
terms of specialist equipment or premises. On this basis, therefore, we believe that
the inclusion of Librarianship in the proposed reductions is an error arising from a
mis-classification by Learn Direct, and one which ought not to be compounded by
the proposed Recurrent Funding model.’
83. A small number of respondents expressed concerns about the use of HECoS codes to inform
OfS funding allocations, arguing that HECoS does not reflect the cost of teaching subjects and
that the use of HECoS for such purposes creates a risk of providers trying to ‘game the
system’:
‘We expressed our concerns when the HESES return moved from funding provision
according to cost centres (and hence cost of provision) to HECoS subject coding, and this
proposal crystallises that concern. Using subject coding to determine funding levels will
potentially compromise the integrity of the HECoS subject coding process if there is a
funding advantage to using particular codes.’
84. Respondents also noted that the use of HECoS and LDCS codes did not sufficiently recognise
differences in how subjects are taught between providers.
‘This approach does not allow for differentiation between how subjects are taught at
different institutions and will encourage a race to the bottom as institutions seek to cut costs
at the expense of the student experience’.
85. A few respondents called for specific measures that could be applied to supplement the
proposed classification:
a. For archaeology:
‘We recommend that the OfS examines archaeology subjects again in the light of our
evidence and, to this end, offer the following suggestions:
A) Retain all archaeology subjects in group C1.1
B) Subdivide archaeology courses between groups C1.1 and C1.2 dependent upon course
content.
We also propose that any course which is [Chartered Institute for Archaeologists]
accredited (i.e. that certifies that it is structured to professional competences for working in
archaeology) should be granted C1.1 status on the basis of this accreditation’.
b. For providers in receipt of the specialist institutions targeted allocation:
‘The use of LDCS and HECoS subject codes is broadly appropriate for this purpose. In
order to avoid detriment to world-leading specialist provision, consideration might be given
to using receipt of the specialist target allocation as a criterion for placing professional
performance training programmes in price group C.1.1 although we appreciate that sub-
splitting the subject areas of dance, drama and music would add complexity to the
methodology; as noted, we would still prefer C1 not to be split nor its funding rate reduced.’
46
86. Finally, several respondents called for an appeal process to be put in place to allow further
information to be submitted on areas of inconsistency.
‘There are boundary issues between CAH levels and price groups and also some
inconsistencies within CAH level. [The provider] would propose consideration to allowing
institutions to make a case for exclusion of individual HECoS codes from the proposed
CAH level 3 subjects highlighted to be removed from price group 1.’
‘We tend to agree with the proposed methodology to allocating the fund based on
HESES20, however there should be an opportunity for providers to request a review of this
if we feel that the likely intakes will be significantly higher.’
OfS response and decisions
87. We have set out under question 2 the decisions we have taken on splitting price group C1
and the reasons for it. This also sets out our position on comments made about phasing
changes to funding over a longer period.
88. We note the small, but not insignificant number of responses, particularly from registered
providers, that approved of the process to define the new price groups using HECoS and
LDCS codes.
89. A number of respondents argued that the proposed approach of using subject codes was
not sophisticated enough or too crude to take account of variations in course content and
delivery between providers, the interdisciplinarity of some courses and their higher cost
content that was closely aligned to science and engineering disciplines. We do not accept
this argument.
90. The approach we take to splitting price group C1 has to be consistent with the approach we
take to assigning activity to price groups more generally and reflect how C1 in particular is
already defined. This is set out in the Higher Education Students Early Statistics (HESES)
survey.53 Actual price group coding is defined by LDCS codes for further education and sixth
form colleges and by HECoS codes for all other providers. Where we discuss subjects in
terms of Common Aggregation Hierarchy (CAH) levels, this is used as a matter of
convenience to allow similar subjects to be discussed together. However, we already
acknowledge several subjects where it is appropriate for different HECoS codes within the
same CAH level code to be assigned to different price groups.
91. Providers themselves determine what HECoS codes should be assigned to their courses,
but in doing so, must follow guidance provided by HESA.54 This states that ‘subject coders
should base their decisions on the academic subject taught or learned, rather than the
pedagogical methods employed’ and also that ‘while providers are given the option to
53 See Annex G of www.officeforstudents.org.uk/publications/heses20/.
54 See www.hesa.ac.uk/support/documentation/hecos/implementation-guide.
47
describe a course, module or qualification using a maximum number of codes,55 it should be
recognised that good subject coding is economical. The number of codes to describe
courses, modules and qualifications should always be minimised in the interests of providing
succinct information for intended users and for consistency across the sector’. The
assignment of subjects to price group C as a whole, and price group C1 within it, already
reflects that such subjects have a laboratory, studio or field work element that gives rise to
higher cost. Where interdisciplinary courses contain content across different subject areas,
that may be reflected in the subject codes used, and therefore the rates of grant provided.
We believe that this approach allows for suitable differentiation between courses with
differing content.
92. As noted in the OfS response and decisions for question 2, the assignment of HECoS codes
for archaeology to price groups already differentiates between forensic and archaeological
sciences (in price group B) and archaeology (in price group C1).
93. We also do not accept that the risk of providers ‘gaming the system’ on the basis of using
HECoS codes is greater than when providers that submit the HESA Student record used
academic cost centres to assign activity to price groups. The use of HECoS codes ensures
greater consistency between providers for funding purposes, recognising that the use of
subject codes has always been the approach for other providers. It also ensures
consistency with the use of courses (rather than the departments in which students are
taught) for other purposes, such as the Teaching Excellence and Student Outcomes
Framework, the National Students Survey, Discover Uni, certain categorisations for the
purposes of student support from the Student Loans Company, and students’ applications
through UCAS. By contrast, academic cost centres did not have any such wider purposes
other than analysis.
94. Providers themselves are responsible for the quality and accuracy of the data they submit to
us and other bodies. We do not approve or agree their data submissions, but we monitor the
reasonableness and credibility of data, including by comparing and reconciling different
datasets and by carrying out audits. We will require providers to amend their data
submissions, if we believe there are errors or inappropriate classifications which would
significantly and materially affect our use of the data. This may include requiring changes to
how providers use subject classifications (whether LDCS or HECoS codes) and hence how
students are assigned to price groups. Providers are also required to meet conditions F3
(provision of information to the OfS) and F4 (provision of information to the designated data
body) as part of their ongoing conditions of registration.56
95. The scope providers have to develop their own curricula is a strength that has contributed to
the success of UK higher education and is to be expected in a higher education market that
is operating effectively. It increases student choice, ensures course content can respond
quickly to the latest developments in research and industry, as well as local employer
needs, and allows for innovation in course delivery. To support such diversity, providers
55 Five to describe a course or a qualification, although more than three qualification subjects would
generally be regarded as exceptional.
56 See: www.officeforstudents.org.uk/publications/securing-student-success-regulatory-framework-for-higher-
education-in-england/.
48
need scope to reflect their own priorities in their use of funding – to decide to invest more in
some subjects or activities than others. It means that there are inevitably variations in costs
not just between subjects, but also between providers within a broad subject area, reflecting
different course content, means of delivery and staffing structures, as well as varying
opportunities for providers to cross-subsidise between their activities and sources of income.
96. We cannot assume that, because one provider is able to offer a subject at a particular (low)
cost, then all providers should be able to do so, because that would be to disregard the
diversity of provision and institutional investment priorities that are so important to a higher
education market functioning effectively. However, it also means that, in the grants we pay,
we are not looking to take account of all the variations in costs between providers that may
exist – rather, we recognise providers’ autonomy in making investment decisions in
particular activities from within the overall resources available to them, to which OfS grant
makes only a relatively small contribution. We also believe that any attempt to take account
of detailed cost variations between providers would involve a very significant accountability
burden on providers to justify their costs and create perverse incentives that would
undermine provider efficiency.
97. Having regard to the responses received to our consultation, our statutory duties, the
funding settlement for the 2021-22 financial year and the terms and conditions of grant
attached to it, we confirm that the subject codes that determine the assignment of activity to
the new price group C1.2 will be as set out in Annex B of our consultation (OfS 2021.01),
but with the exception of codes relating to archaeology, which will now map to price group
C1.1 instead of C1.2.57
Question 4: To what extent do you agree with our approach to counting students from the Crown Dependencies in our funding allocations for 2021-22?
98. Table A5 summarises the extent to which respondents to the consultation agreed or disagreed
with the proposal, or neither.
Table A5: Numerical summary of responses to question 4
Respondent type Strongly agree
Tend to agree Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
31 (26.1%) 57 (47.9%) 3 (2.5%) 6 (5.0%) 22 (18.5%)
On behalf of other organisation
12 (7.1%) 35 (20.8%) 4 (2.4%) 11 (6.5%) 106 (63.1%)
As an individual 296 (3.9%) 1177 (15.7%) 420 (5.6%) 928 (12.4%) 4683 (62.4%)
All respondents 339 (4.4%) 1269 (16.3%) 427 (5.5%) 945 (12.1%) 4811 (61.8%)
57 The archaeology subject codes that this applies to are, for further education and sixth form colleges, the
Learn Direct Classification System (LDCS) code DC and, for other providers, the Common Aggregation
Hierarchy (CAH) code CAH20-01-03.
49
99. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer not
to say’ are discounted), 54 per cent of respondents agreed with the proposals and 46 per cent
disagreed. We received 1,171 comments in response to this question.
100. More than 50 per cent of the comments received were in favour of the proposals.
Respondents noted that, in light of the government decision making students from the crown
dependencies eligible for home fee status from 2021-22, ‘[as] these will be “home” fee level
students, it only makes sense to count them in funding allocations.’
101. A small number of respondents discussed our proposed funding methods; those that did
considered it ‘to be pragmatic and we appreciate the aim is to avoid the need for any new data
collection’. One provider asked for further detail on these methods, noting that:
‘…the method of calculating the number of such students for funding in 2021-22 set out in
the consultation (i.e. using the individualised student data returns for 2019-20) is
problematic for [providers] that did not return these students as part of the Student
Alternative return.’
102. Around 25 per cent of respondents, including both those that agreed and disagreed with the
proposals, expressed concerns that including these students in our funding calculations would
dilute the rate of funding available for existing home students. Concerns were also expressed
that the increased costs of including crown dependencies students were being met through
reductions in other areas, such as the reduction to the rate of high-cost subject funding for
price group C1.2. General calls were made for an overall increase in funding to be made
available to support this:
‘We would support [the proposal] on the basis that the Government provides additional
funding to resource the additional estimated 3,000 FTE students. Failure to do so would
obviously dilute the resources available for existing students, at a time when funding
resources are already under pressure’.
103. Around 5 per cent of respondents commented on the independent status of the crown
dependencies, noting that:
‘… these self-governing dependencies of the Crown operate their own fiscal system
independent, and in competition with the UK. It would therefore be entirely reasonable and
equitable for these Government[s] to contribute to the costs of funding their residents, and
not the UK taxpayers.’
One specific provider noted that it ‘historically recruited strongly from the Isle of Man’ and that it
estimated that the proposals would result in a not insignificant loss of fee income of around
£107,000.
104. A small number of respondents appeared to be confusing ‘Crown Dependencies’ with
‘commonwealth countries’, and a larger minority appeared to be conflating the proposal with
larger issues around EU students no longer qualifying as eligible to receive student support,
such as tuition fee loans.
50
OfS response and decisions
105. We welcome the general support for the proposals to include students from the crown
dependencies in our funding allocations.
106. Though we recognise the concerns from some respondents, we do not believe these
proposals will result in a significant reduction to the rate of funding providers will receive,
albeit that this is in the context of reduced funding per FTE arising from substantial
increases in student numbers arising for other reasons. As shown in Table 3 of this
document, the estimated number of students from the crown dependencies represents only
3.6 per cent of the additional student FTEs that we need to count for 2021-22.
107. We note the concern of one provider over the use of 2019-20 individualised data to
estimate student numbers from the Crown Dependencies on the basis that it had not
reported such students in its HESA Student Alternative return. We believe these students
were not reported because they were studying wholly outside the UK for the duration of their
studies (that is, by distance learning). We have clarified with the Department for Education
that students from the Crown Dependencies that are studying by distance learning will be
subject to home fees only if they are doing so from within the UK (rather than from the
islands). For those studying outside the UK, there is no change to their fee status and
therefore we will continue not to count them for funding purposes.
108. The question of whether additional funding can be obtained from the UK government or
from the governments of the Crown Dependencies, is outside the scope of OfS decisions.
109. Having regard to the responses received to our consultation and our statutory duties, we
confirm that we will count for 2021-22 funding purposes students from the Crown
Dependencies whose eligibility for home fees will change from 2021-22. If we did not, the
providers that have such students would be unfairly disadvantaged by the loss of fee income
arising from the new restriction on the fees that they could charge. We will estimate the
numbers of such students (by price group, mode and level) using 2019-20 individualised
student data.
110. If providers believe that their 2019-20 individualised student data does not capture the
population of students from the Crown Dependencies whose fee status will change from
2021-22, they should contact [email protected] to discuss the
situation. We will look to ensure that we make appropriate adjustments to the students we
count for funding purposes for all providers to reflect the population of students affected by
the changed fee status of students from the Crown Dependencies.
51
Question 5: To what extent do you agree with the proposed approach to remove the targeted allocation for students attending courses in London?
111. Table A6 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
Table A6: Numerical summary of responses to question 5
Respondent type Strongly agree
Tend to agree
Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
28 (23.5%) 25 (21.0%) 13 (10.9%) 38 (31.9%) 15 (12.6%)
On behalf of other organisation
6 (3.6%) 4 (2.4%) 19 (11.5%) 61 (37.0%) 75 (45.5%)
As an individual 110 (1.6%) 481 (6.8%) 1059 (15.0%) 2235 (31.7%) 3155 (44.8%)
All respondents 144 (2.0%) 510 (7.0%) 1091 (14.9%) 2334 (31.9%) 3245 (44.3%)
112. We also received 2,118 comments in response to this question. Of the respondents that
expressed a view (that is, when responses of ‘don’t know / prefer not to say’ are discounted),
16 per cent of respondents agreed with the proposals and 84 per cent disagreed.
113. The main themes identified in these comments were:
a. There are additional costs (for providers and students) of higher education in London, and
respondents discussed the impact of removing the targeted allocation that recognises those
costs for providers.
b. The removal of the allocation is reasonable given the restraints on the funding, and it will
likely be helpful to providers who are based outside of London.
c. The impact that removing the targeted allocation may have on access and participation
objectives.
d. That London-based providers offering subjects in price group C1.2 will be facing a double
cut in funding for many of their courses.
e. Small and specialist London-based providers are more likely to be impacted by the results
of the removal of the targeted allocation.
f. A theme raised by respondents was if the removal of London weighting was implemented
there should be consideration of phasing the change over two or more years. This was
noted to be particularly relevant as providers would have very little time between being
informed of the decisions (July 2021) and the reductions happening (from August 2021).
114. More than 50 per cent of responses were critical of the proposal to remove London
weighting, with several key themes discussed. A primary concern was the additional costs of
study in London. Several responses cited the KPMG report referenced in our main consultation
document, which found the unit of cost per student FTE of undergraduate teaching was 14 per
52
cent higher in London than the England average.58 Reponses, particularly those from
registered providers noted that these represented substantial and real extra costs, and that
removing the London weighting allocation would only increase the financial pressures they
faced.
‘The London weighting supports institutions where the cost of delivering courses is higher
than elsewhere in the country. This includes the cost of employing staff, of renting or buying
real estate, of equipment, of materials, labour and expertise. It includes the cost of food, of
consumables of all kinds and of services that are needed. Finally, it includes increased
costs associated with travel, whether using public transport or other means.’
‘Costs in London are higher than the rest of England and HE providers are legally obligated
to pay an additional London weighting salary to all staff which substantially increases their
workforce costs.’
115. Respondents also argued that any reduction or removal of the London allocation will result
in reduced course quality and student experience. It was noted that staff costs represent a high
proportion of a provider’s operating costs, and that providers may have to respond to reduced
OfS funding by cutting staff costs, either through reduced pay or redundancies, with a reduction
in academic and student support staff across the capital. This reduction in quality and
experience may then reduce the number of students wishing to attend courses in London,
further driving financial problems.
‘Removing the targeted allocation for students attending courses in London will have an
impact on students, damaging the student experience as well as, potentially, the outcomes
that students achieve. Removing significant funding at such short notice will require
immediate action such as cutting staff cost as other costs are harder to control in the short
term. Reducing staff costs will mean reducing pay, where possible, or reducing headcount
or some combination of both. Both have an impact on staff morale and the quality of service
provided to students, ultimately negatively affecting the student experience. Removing the
London weighting risks penalising students since less funding is likely to mean less
spending per student.’
‘The London weighting was put in place to recognise that the country does not have an
equal cost of living in each of its regions. As the consultation acknowledges, this has not
changed. In fact, the costs of delivering teaching in London are getting higher. Removing
the London weighting will therefore have a significant impact on students studying in the
capital and could result in institutions become so financially unsustainable they may have to
lose staff, close courses, departments or even the whole university.’
116. Several respondents were critical of the view that they could find more income by recruiting
more international students. Commenters noted the variety of higher education providers
58 A 2019 report by KPMG commissioned by the Department for Education as part of the supporting
evidence for the Augar report, available at: www.gov.uk/government/publications/cost-ofundergraduate-
higher-education-provision. See in particular section 7.10.
53
across the capital, and that a number of providers did not have the capacity or desire to attract
significant numbers of international students.
‘Whilst it is true that some London institutions capitalise on their location to recruit
international students, that is not universally the case […] for the vast majority of HE
providers in London [reductions in OfS funding] cannot be recuperated through increasing
international student numbers.’
‘Course numbers on specialist courses are strictly limited and cannot be expanded. Altering
the balance of home to overseas students on specialist courses will not be in the interest of
industry needs within the UK.’
‘It is important to note too, that International students are not equally distributed across
London HEIs; many have low numbers of international students. The NHS depends on
London’s health HE provision (London HEIs educate a significant proportion; some courses
are already loss-making).’
Comments also noted that during the ongoing coronavirus pandemic international student
numbers are not stable and therefore should not be relied upon to make up for the removal of
this funding.
117. A number of respondents noted that providers operating in London provide courses that
train key workers and that reductions to London weighting will affect the viability of these
courses. It was also pointed out that medical and dental subjects face specific limits on
international recruitment.
‘Higher education providers which are teaching-intensive by nature are likely to be
disproportionately affected – these often train key workers such as teachers, social care
workers, healthcare workers and medical staff. Some of these courses are already loss
making, yet are provided because they feed into shortage occupations for the NHS.
Removing the London weighting will make these types of courses even less viable and, due
to caps on international student places in many of these strategic priority subject areas,
providers have no way of recouping costs as has been claimed. While the consultation
claims that funding will be reprioritised, London institutions within the capital that contribute
to the national priorities of healthcare and medicine will all be net losers from this proposal.’
118. One provider noted the role that London weighting has played in maintaining the rate of
funding for students on medical and healthcare courses. They noted that, under the proposals,
they expected their courses in price group A to see a reduction of £1,187 (10.5 per cent) for
2021-22 compared with 2019-20. They also noted that this conflicted with statements from the
government, provided in August 2020 that noted ‘[we] will provide additional funding through
the Teaching Grant in line with existing per student rates to support the delivery of [medical and
dental] courses.’
119. Whilst many respondents praised the efforts to increase the available funding across
England, they strongly felt that it should not come from the removal of the London weighting,
which they see as levelling down one region to level up others. They asked that additional
funds be given to achieve such objectives, not just the redistribution of existing allocations.
54
‘Rather than supporting levelling up, it would risk harming the student experience for those
studying in London.’
120. Many respondents argued that the removal of the whole targeted allocation with only a few
months’ notice until the next academic year may lead to the destabilisation of some providers
and possibly the London higher education sector. Other respondents that otherwise agreed,
reluctantly or otherwise, with the proposals to remove the London weighting also said that any
such removal should be phased over two to five years.
‘The removal of all the targeted allocation in one year makes it difficult for these institutions
to find alternative sources of funding to mitigate the impact on students and on subject
areas of national importance’.
‘This change, if it is to go ahead, should be phased in over two or three years […] this cut is
a net loss of over one per cent of turnover in one year with six months’ notice, which is
difficult to manage alongside Covid-related challenges.’
121. Around a third of providers voiced their concerns regarding accessibility of higher education
in the capital if the removal of the targeted allocation went ahead. A primary concern voiced by
respondents was a negative impact on access and participation efforts, due to the removal of
the targeted allocation. Comments noted that the allocation’s removal could cause a decline in
the number of black, Asian and minority ethnic (BAME) students and those from lower
socioeconomic backgrounds attending higher education in the capital.
‘We believe that this a regressive policy that will further disadvantage those already
disadvantaged and will particularly impact London higher education institutions’ support for
widening participation.’
‘London HEIs have some of the most diverse student populations and the highest
percentage of disadvantaged students. Just under 20 per cent of London boroughs are in
the bottom 10 per cent most deprived in terms of average income. Many disadvantaged
London students live at home and study locally. For [this provider] in particular, the largest
percentage of our disadvantaged students come from London. The highest percentage are
BAME. All our students on specific [widening participation] extended medical programmes
will be directly affected. We have [a] large percentage of BAME students on medical,
nursing, and allied healthcare programmes who will be affected.’
122. Many pointed out that courses in London, particularly those in the arts, would become an
‘enclave for the wealthy’ as many students would not be able to afford to study in London
without monetary help from their providers. Many students from outside of London would not
be able to cover the higher living costs that come with higher education study in London.
123. Respondents also commented that there is a wealth disparity across London and that
several of the most deprived boroughs in England are located in London. They argued that
without a London allocation many prospective students from these boroughs would be unable
to attend higher education in general as they may be unable or unwilling to leave the capital for
higher education and would thus forego higher education without the targeted allocation.
‘One third of London boroughs are in the 30 per cent most deprived areas in England […]
53 per cent of our students received Free School Meals (the highest amongst all UK
55
universities), most are commuters and more than 80 per cent fall within at least one
widening participation category. Our students would not have the flexibility to simply move
to another university outside London and, if unable to afford studying at their local London
institution, would likely drop out of higher education altogether.’
‘This will hit the education of often local populations of diverse students within the London
area, and add to the disadvantages faced by the thousands of commuter students in the
Greater London area.’
124. A substantial minority (23 per cent) of respondents commented on their support for the
removal of the targeted allocation, although some of this support was caveated. The levelling
up agenda was mentioned by many respondents, who noted that the removal of the London
allocation will allow a more equitable distribution of funding across England, in line with
government goals. Several respondents advocated for a weighting system to account for
higher costs at various locations across England, such as Brighton, Bristol and Oxford.
‘Living costs in Bristol, particularly with two strong and thriving universities with over 60,000
students, are equally high if not more so in the areas of Bristol that students are based.’
‘Areas of the South East is as expensive for employers and students as London. This is no
longer justified for London only HEIs.’
‘Over time, we would hope that a more distributive model would enhance the viability and
appeal of English higher education, which in turn would benefit all universities, including
those in London.’
125. Respondents in favour of the proposals were sympathetic towards London providers that
may be facing a reduction to their funding but felt that they were in a stronger position to
diversify their income streams, including through recruitment of international students. Several
pointed out that London providers are also aided by the higher level of higher education
participation in the capital compared with the rest of England. And a few respondents noted
that those London providers offering high-cost subjects would be likely to have a smaller
reduction due to the increase to high-cost subject funding. Several respondents commented
that they believe it is correct to prioritise high-cost subject funding over the targeted allocation
when we have a fixed budget.
126. A large number of respondents noted that London-based providers that specialise in, or
offer a high number of, arts courses will face a particularly significant decrease in their OfS
funding, with the removal of London weighting compounded by reductions to the rate of funding
for price group C1.2 subjects. Commenters noted that they have had little warning for this cut.
OfS response and decisions
127. We have noted the arguments presented by respondents relating to the additional costs
for providers of operating in London and for students studying there and the variable extent
to which providers may benefit from being in London by recruiting international students. We
note also the arguments made about the potential impact that the removal of the targeted
allocation for students attending courses in London may have on staffing and provision for
56
students, including in addressing the needs of minority ethnic students and students from
disadvantaged backgrounds.
128. The terms and conditions that the Secretary of State has applied to OfS grant for
2021-22 mean that we must not vary rates of grant, either directly or indirectly, on the basis
of the region of the UK in which providers or students are located or courses offered. They
also preclude us from phasing out London weighting in our allocations over more than one
year. As we note above, terms and conditions issued under section 74 HERA impose a
statutory obligation on the OfS to distribute funding in a particular way. While we have had
regard to all relevant statutory duties in developing our proposals, we ultimately had to fully
comply with the terms and conditions of funding imposed by the Secretary of State in
arriving at the decisions set out in this document.
129. If we do not comply, we may be required to repay the whole or any part of the grant still
held by us to the Department of Education
130. While we understand the concerns raised regarding the particular burden of reductions
in funding to London based providers, the OfS must act in accordance with the terms and
conditions applied by the Secretary of State, to implement the reduction to the high-cost
subject funding rates of grant for performing and creative arts and media studies and to
increase by £10 million the separate funding allocation provided to world-leading specialist
providers.
131. For this reason, we confirm that for academic year 2021-22 we will no longer provide the
targeted allocation for students attending courses in London. This releases the £64 million
that has been provided in academic year 2020-21 for redistribution among all providers
through other elements of grant.
132. We have also noted arguments made by some respondents about the additional costs of
operating in other parts of England outside London. While acknowledging that there will be
other regional cost variations and different factors that contribute to them, we would observe
that evidence from recent studies does not suggest those costs are as high as in London.59
In any event, the terms and conditions of grant placed on us by the Secretary of State
preclude us from varying rates of grant on the basis of any regional location, not just London
and therefore we will not do so.
Question 6: To what extent do you agree with the proposed approach to remove London weighting from the formula-based student premium allocations?
133. Table A7 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
59 See: ‘Regional variation in costs and benefits for higher education providers in England’, available at
webarchive.nationalarchives.gov.uk/20180405115447/http://www.hefce.ac.uk/pubs/rereports/year/2017/regio
nal/ and ‘Understanding costs of undergraduate provision in higher education’, available at
www.gov.uk/government/publications/cost-of-undergraduate-higher-education-provision.
57
Table A7: Numerical summary of responses to question 6
Respondent type Strongly agree
Tend to agree
Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
25 (21.0%) 30 (25.2%) 15 (12.6%) 37 (31.1%) 12 (10.1%)
On behalf of other organisation
8 (4.8%) 5 (3.0%) 18 (10.9%) 60 (36.4%) 74 (44.8%)
As an individual 123 (1.7%) 368 (5.2%) 983 (14.0%) 2587 (36.8%) 2976 (42.3%)
All respondents 156 (2.1%) 403 (5.5%) 1016 (13.9%) 2684 (36.7%) 3062 (41.8%)
134. We received 1,809 comments in response to this question. Of the respondents that
expressed a view (that is, when responses of ‘don’t know / prefer not to say’ are discounted),
13 per cent of respondents agreed with the proposals and 87 per cent disagreed.
135. There was substantial overlap in the responses to this question with themes identified in
question 5: around a quarter of responses specifically referred us to their previous answer. In
addition to the themes identified in question 5, a number of other themes were noted that
specifically related to London weighting and the student premiums. A small number of
respondents noted a conflict between removing London weighting and the OfS’s stated
priorities:
‘In paragraph 12c of the consultation, the OfS reminds us that it’s priorities include: “To
protect as far as possible the total funding that we allocate towards providers’ activities to
improve access and support student success”. Removal of the London weighting element
goes against this principle and makes it significantly more difficult for London providers to
undertake activities which support this priority: these activities cost more in London.’
136. Several respondents reiterated concerns about how proposals would threaten their access
and participation efforts:
‘Removal of the London weighting from formula-based student premiums may threaten
widening participation goals given the probable impact on student support. London has a
proportionately higher volume of commuting students and students from under-represented
groups who have also been disproportionately affected by the pandemic. As such this
would have inequitable impact which is out of kilter with OfS approach to equality and
widening participation.’
‘The removal of the London weighting from the formula-based student premium allocations
takes important support away from Londoners from the lowest socio-economic groups who
wish to study close to home, saving significant amounts of money by choosing to commute
locally for higher study’.
137. A small number of respondents reiterated that students from certain areas of London face
particular challenges and that reductions in student premiums due to the removal of London
weighting will significantly disadvantage providers that serve these areas. One provider went
58
further and noted that the London weighting for student premiums should be preserved in
preference to the London targeted allocation.
‘We agree with the analysis by London Higher which shows that WP [Widening
Participation] students will be significantly disadvantaged by a cut to London weighting,
especially in relation to the student premium. Some London boroughs contain some of the
most deprived students in the country. We know that disadvantaged students tend to stay
local to attend university, and this standard behaviour for WP students in London who are
nearly always commuters […] Whilst we don’t agree that London weighting should be cut at
all, we fundamentally believe that it should be retained for the student premium allocation,
to recognise that some London HEIs are doing meaningful and significant work to improve
the quality of life for disadvantaged students in London, especially those from non-white
communities.’
138. Some respondents noted that London weighting is an established concept outside of higher
education, and questioned why it should not be accounted for in OfS funding.
‘We strongly disagree with the proposed approach to remove the London weighting from
the student premium allocations. This removal is not applied to other sectors and we query
why it is proposed for higher education. Land and building costs in inner London are more
than three times greater than the national average, average academic staff costs in inner
London are 12 to 14 per cent higher than the national average and the cost of higher
education provision in London 14.1 per cent higher than the England average. The cost of
London weighting that we pay as part of staff salaries significantly outweighs the London
weighting funding received, even before the other items mentioned are taken into account.’
139. As with question 5, respondents also noted the short notice provided for changes and
requested measures be put in place to mitigate reductions to specific providers:
‘Although we recognise some costs may be higher HEIs in London do have an enhanced
ability to recruit both international and home students compared to other parts of the
country due purely to their location and therefore should not be prioritised for OfS funding
when cuts are being made to areas such as Student Access and Success. However, we
also believe that as a principle any removals of specific allocations should be phased in so
as to limit the impact on any particular provider.’
OfS response and decisions
140. As with the responses to question 5, we have noted the arguments presented by
respondents relating to the additional costs for providers of operating in London and for
students studying there. We also note the potential impact that the removal of London
weighting in the student premium allocations may have on the work providers do in
addressing the needs of minority ethnic students and students from disadvantaged
backgrounds.
141. The terms and conditions that the Secretary of State has applied to OfS grant for
2021-22 mean that we must not vary rates of grant, either directly or indirectly, on the basis
of the region of the UK in which providers or students are located or courses offered. It also
precludes us from phasing out London weighting in our allocations over more than one year.
59
If we do not comply, we may be required to repay the whole or any part of the grant still held
by us to the Department of Education. As we note above, terms and conditions issued
under section 74 of HERA impose a statutory obligation on the OfS to distribute funding in a
particular way. While we have had regard to all relevant statutory duties in developing our
proposals, we ultimately had to fully comply with the terms and conditions of funding
imposed by the Secretary of State in arriving at the decisions set out in this document.
142. For this reason, we confirm that for academic year 2021-22 we will no longer include
London weighting in calculating student premium funding allocations.
143. We note the concerns from some respondents that the removal of London weighting
from the student premium allocations would be in conflict with our priority ‘to protect as far
as possible the total funding that we allocate towards providers’ activities to improve access
and support student success’ (see paragraph 135, above). As above, the terms and
conditions of funding imposed by the Secretary of State require us to remove London
weighting. However, we consider that our priority ‘to protect as far as possible the total
funding that we allocate towards providers’ is reflected in our decision to provide a total of
£313 million in funding for student access and success, a reduction of 1 per cent compared
with the £316 million provided in 2020-21 – see Table 4.60 It does not mean that there
should be no redistribution of funding between the budgets that contribute to the total, nor
between providers within each budget.
Question 7: To what extent do you agree with the proposal to provide £40 million to support Uni Connect activities in 2021-22?
144. Table A8 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
Table A8: Numerical summary of responses to question 7
Respondent type Strongly agree
Tend to agree Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
17 (14.3%) 54 (45.4%) 17 (14.3%) 14 (11.8%) 17 (14.3%)
On behalf of other organisation
10 (6.1%) 25 (15.2%) 14 (8.5%) 19 (11.5%) 97 (58.8%)
As an individual 427 (6.4%) 1184 (17.7%) 410 (6.1%) 721 (10.8%) 3932 (58.9%)
All respondents 454 (6.5%) 1263 (18.2%) 441 (6.3%) 754 (10.8%) 4046 (58.1%)
145. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer
not to say’ are discounted), 59 per cent of respondents agreed with the proposals and 41 per
cent disagreed. We received 1,289 comments in response to this question.
60 This comparison does not take account of the one-off allocation of £85 million of hardship funding provided
in academic year 2020-21 as a result of the impact on students of the coronavirus pandemic.
60
146. Around a third (32 per cent) of the responses received expressed concerns with the
reduction in funding to the Uni Connect programme, with a quarter calling for the level of
funding to stay at its current level or be increased. Respondents noted that:
a. The Uni Connect programme has delivered proven positive outcomes, both at a national
and partnerships level and with particular priority groups. Respondents commented that a
reduction in programme funding would put this progress at risk.
b. Reductions in programme funding will mean cuts to programme budgets and staff, with a
corresponding loss of expertise. Respondents also noted that this has been exacerbated by
the necessity to make decisions on the Uni Connect budget later than expected in the year.
It was also noted that access to funding to support outreach activity is particularly important
for smaller providers such as further education colleges. Outreach activity by these smaller
providers could be jeopardised by reductions to the Uni Connect budget.
c. A reduction in funding for Uni Connect activities would be incompatible with government
and OfS policy priorities. It was noted that the reduction would not support our policy
priorities to ‘protect as far as possible the total funding that we allocate towards providers’
activities to improve access and support student success’ and that it sent a ‘concerning
signal about the OfS and Government commitment to widening participation in higher
education.’ Respondents noted that the OfS is looking to expand the programme to include
more further education students, care experienced students and adult learners and that it
will be extremely difficult for partnerships to deliver everything proposed on a significantly
reduced budget.
d. Providers’ access and participation plans are not sufficient to meet the OfS’ strategic
objectives alone. It was noted by one respondent that Uni Connect-related activity
accounted for ‘42 per cent of outreach activities recorded on the HEAT61 databases’ and
that ‘as many as 60,000 learners are likely to miss out on receiving support to progress to
Higher Education in 2021-22 due to the proposed reduction in funding’. It was noted that
this reduction in support would disproportionately affect the areas of England and the
groups of learners who are most underrepresented in higher education.
e. The COVID-19 pandemic is expected to have a disproportionate impact on the
programme’s target learners. Respondents noted that Uni Connect partnerships would
want to scale back up their delivery and recover any missed opportunities to make up for
the disruptive effects of the pandemic on educational disparities (such as attainment gaps)
and on the larger economy and jobs market.
147. A small number of responses noted that it was appropriate to reduce funding for the
programme now it was more firmly established. Respondents also recognised that while
funding reductions were regrettable, rebalancing investment towards student success would
help address the growing financial and mental health crisis for students who are currently in
higher education.
148. A number of respondents provided further comments relating to the timing of funding
announcements relating to Uni Connect funding. Responses noted that a lack of certainty of
61 Higher Education Access Tracker – see heat.ac.uk/
61
the level of funding for the programme in future years introduced a level of instability to their
offering: employing staff on fixed-term contracts had ‘a significant impact on [the] ability to
attract and retain knowledgeable and experienced staff’ and put ‘established relationships with
schools/colleges at risk’. Respondents discussed the benefits of funding over a longer term,
enabling partnerships and stakeholders to plan and manage staff resources and commit to
longer term collaborative work. They also mentioned the benefits of early clarity on how
programme targeting might operate in the future and the importance of clear guidance from the
OfS on the intended use of Uni Connect funding.
149. A small number of respondents took the opportunity to suggest alternative approaches to
widening access to higher education that they felt would be a better use of resource than
supporting the Uni Connect programme. These included: lowering tuition fees and increasing
student grants; providing funding directly to higher education providers; investing in other
collaborative approaches; strengthening expectations of providers around student support;
restricting funding to providers with a track record of successful outreach programmes; and
increasing funding for transitional courses and foundation programmes.
150. Slightly more than 20 per cent of all respondents argued that the consultation question was
misleading as it didn’t explicitly mention that the funding level proposed was a reduction, with
the majority of these respondents using the same ‘stock’ wording. A small number of
respondents argued that the rationale for rebalancing funding away from ‘access’ and towards
later steps in the student lifecycle was not fully explored in the consultation document. A very
small number of respondents argued that more consultation was required to understand the
impact of the reduction.
OfS response and decisions
151. Respondents made a number of arguments about the consequences of a reduced
budget for the Uni Connect programme, compared with 2020-21, in particular highlighting
the reduction in their outreach activity that might become necessary. We acknowledge that
the proposed budget may lead to a reduction in the overall level of activity within the
programme. However, we do not intend to change programme targeting or reduce our
ambition around the number of learners who will be engaged during 2021-22. We believe
that the Uni Connect partnerships can continue to meet our goals through a combination of
increased efficiency and a focus on the most effective interventions. This will be informed by
the sizeable body of evaluation and effective practice evidence that has been generated
during phases one and two of the programme. Uni Connect will therefore continue to ensure
that information, advice and guidance and outreach are targeted on the areas and groups
where they can have the greatest impact using the most effective approaches, including
activity to address the impact of the pandemic on target learners.
152. We do not accept that funding reductions will disproportionately impact on smaller
providers such as further education colleges. Partnerships will make decisions about how
they use the funding that is available but our ambition, clearly set out in our response to the
Uni Connect consultation,62 is that we expect an increased emphasis on the role and
62 See: www.officeforstudents.org.uk/publications/a-new-approach-to-the-uni-connect-programme-from-
2021-22-to-2024-25/.
62
contribution of further education colleges in phase three of the programme. We have also
emphasised the importance of collaboration across and between partnerships around
subject specialist pathways which we expect to facilitate the engagement of smaller subject
specialist providers in a more efficient and effective way.
153. As set out in the OfS response on question 6, our policy aim of protecting as far as
possible the total funding that we allocate towards providers' activities to improve access
and support student success, does not mean that there should be no redistribution of
funding between the budgets that contribute to the total. Our proposals achieve the policy
aim while, as set out above, sustaining progress within the programme, albeit within a
reduced budget for Uni Connect.
154. We do not accept that our question on Uni Connect was misleading in not being explicit
that the proposed budget was a reduction. Paragraph 63 of the consultation document
proposed that ‘the allocation for Uni Connect is reduced to £40 million, a reduction of one-
third’, and the consultation question referred to this paragraph. In addition, the proposed
change to the Uni Connect budget was set out explicitly in Table 4 of the consultation
document, which compared all recurrent budgets for 2020-21 and proposed for 2021-22.
155. Some respondents suggested alternative approaches to supporting access, rather than
through the Uni Connect programme. Some of these alternatives were outside the scope of
our consultation: for example, the balance of student finance between grants and loans is a
matter for the government. Where OfS funding is concerned, our view remains that support
for student access can be achieved most efficiently and effectively when providers work
collaboratively together through targeted approaches, as Uni Connect partnerships do. This
also better supports the provision of impartial advice to students. Our proposals were also
efficient in building on the experience and infrastructure developed during the earlier years
of the programme. We do not believe that the responses received against our proposal
made a compelling case for an alternative and the majority of respondents who gave a view
supported the proposal.
156. Having regard to the responses received to our consultation and our duties, we confirm
that the overall budget for Uni Connect for 2021-22 is £40 million.
Question 8: To what extent do you agree with the proposal to distribute an additional £5 million through the existing student premiums in the proportions shown in [paragraph Error! Reference source not found. of the consultation document], and to earmark this £5 million to be spent on student hardship?
157. Table A9 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
Table A9: Numerical summary of responses to question 8
Respondent type Strongly agree
Tend to agree Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
41 (34.5%) 56 (47.1%) 8 (6.7%) 4 (3.4%) 10 (8.4%)
On behalf of other organisation
24 (14.5%) 41 (24.8%) 12 (7.3%) 5 (3.0%) 83 (50.3%)
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Respondent type Strongly agree
Tend to agree Tend to disagree
Strongly disagree
Don’t know / prefer not to say
As an individual 711 (10.7%) 2101 (31.5%) 321 (4.8%) 341 (5.1%) 3197 (47.9%)
All respondents 776 (11.2%) 2198 (31.6%) 341 (4.9%) 350 (5.0%) 3290 (47.3%)
158. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer
not to say’ are discounted), 81 per cent of respondents agreed with the proposals and 19 per
cent disagreed. We received 1,444 comments in response to this question.
159. The most common theme, expressed by 26 per cent of respondents, was that the additional
£5 million to be distributed was not a sufficiently large amount to address ongoing student
hardship in light of the COVID-19 pandemic. It was noted that this is significantly lower than the
£85 million made available for 2020-21 by the Department for Education through the OfS, with
calls that:
‘… as a minimum the funding should reflect the 2020-21 level given the significant hardship
being felt by students from the on-going impact of the pandemic in relation to job
opportunities for students to support their studies and increased unemployment affecting
household income’.
160. The proposal to provide additional funding for this purpose was broadly welcomed by
respondents, but several expressed a belief that ‘in practice the additional sums reaching each
student in real hardship is unlikely to be significant.’
Respondents also noted that the increased funds available for this funding stream had been
produced as a result of reductions in other areas, particularly London weightings and the
reduction in the rate of high-cost subject funding for price group C1.2.
161. It was noted that for certain providers and student groups this would not result in a net
benefit. The focus of a larger proportion of the hardship funding towards full-time students was
not felt to recognise that:
‘Those in lowest socio-economic groups are more likely to stay at their homes and
commute to their local HEP and/or study part-time […] this combined with the removal of
the London weighting disproportionately places the burden of this funding changes on
students from some of the most deprived areas of the country and thus exacerbates
inequality rather than help level up society.’
162. Multiple respondents, particularly those providing an official response on behalf of a
provider, noted that the proposed formula allocation method was a ‘sensible approach which
does not add any further burden and can be implemented in a short period.’ It was further
noted that the inclusion of this element of funding within the main grant announcement was
welcome, rather than as a ‘late in-year initiative’. Respondents felt that having some certainty
of their allocation early in the year allowed for more effective planning and use of the available
funds.
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163. Respondents also expressed a desire for any terms and conditions placed on the use of
hardship funding allocations to be as broad as possible, noting that ‘smaller pots of funding
attached to specific requirements are not as impactful as the resource required to implement
them mitigates their impact on students.’ Respondents called for the OfS to provide as much
flexibility as possible on the use of this funding, with concerns raised including:
a. Clarification on whether the funding could, as with the 2020-21 hardship funding
allocations, be used for ‘a wider population of higher education students than those counted
in our student premium funding methods including, for example, postgraduates (whether
taught or research), overseas students and others that do not meet the definition of ‘OfS-
fundable.’
b. Timescales for the use of the funds should be ‘realistic’.
c. That use of the funding should not be earmarked specifically for student hardship, but
providers should be given flexibility to allocate the funding locally, to best support the
priorities of their access and participation plan and the needs of their student body.
164. One respondent called for a change to our funding methods that would allow student
opportunity funding to be ‘made available to students at all providers registered with the OfS
and not just those at Approved (fee cap) providers’.
OfS response and decisions
165. Several respondents noted that the amount of additional funding per student would be
low: ‘in crude terms extra funding of £5m equates to less than £3 per student’. We note that
this does not reflect the intention that this funding should be targeted to support those
students that need it most. The approach set out in our proposals, with student hardship
funding allocations reflecting the existing student premium calculation method, will allow
hardship funding to be targeted towards providers with a greater proportion of
disadvantaged students.
166. The total budget available for this funding stream has to be considered within the context
of the entire recurrent funding budget package. We note that the amount available to
support hardship funding is lower than that made available for 2020-21. But it should be
noted that the £85 million for 2020-21 was provided as a one-off allocation made from
outside of the main OfS recurrent funding budget, and was intended to recognise the
immediate effects of the COVID pandemic and resulting lockdown restrictions. £5 million
does not represent a limit on what providers will make available to students facing hardship
– we recognise that providers already offer hardship funding to students, which can be
financed from OfS student premium funding as well as other income available to them, such
as course fees and endowments.
167. We note the concerns of respondents about flexibility in how this funding can be used.
We confirm that this funding must be used during the 2021-22 academic year to address
hardship faced by students and, as such, must be distributed to students in this period and
not used to support providers’ own costs. As with the one-off hardship funding distributed for
2020-21, we confirm that providers may use it for a wider population of higher education
students than those counted in our student premium funding methods including, for
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example, postgraduates (whether taught or research), overseas students and others that do
not meet the definition of OfS-fundable.
168. We are not empowered to fund directly providers that are not registered with us in the
Approved (fee cap) category and this includes in relation to hardship funding for students.
169. Having regard to the responses received to our consultation and our duties, we confirm
that we will provide an additional £5 million to address student hardship in academic year
2021-22. We will allocate this to providers through the full-time, part-time and disabled
student premium funding methods, as proposed in our consultation.
Question 9: To what extent do you agree with the proposals to distribute £15 million to address student transition and mental health, through a combination of competition and a new formula-based student premium?
170. Table A10 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
Table A10: Numerical summary of responses to question 9
Respondent type Strongly agree
Tend to agree Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
42 (35.3%) 59 (49.6%) 6 (5.0%) 2 (1.7%) 10 (8.4%)
On behalf of other organisation
25 (15.2%) 42 (25.5%) 6 (3.6%) 11 (6.7%) 81 (49.1%)
As an individual 656 (9.8%) 1760 (26.4%) 610 (9.1%) 505 (7.6%) 3138 (47.1%)
All respondents 723 (10.4%) 1861 (26.8%) 622 (8.9%) 518 (7.5%) 3229 (46.4%)
171. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer
not to say’ are discounted), 69 per cent of respondents agreed with the proposals and 31 per
cent disagreed. We received 1,653 comments in response to this question.
172. Of the respondents that provided comments, more than 50 per cent were in favour of the
proposals, noting the value of providing specific funding to support student transition and
mental health initiatives. Many respondents discussed the need for such measures, given the
current pressures on students and their mental health. It was noted that ‘students are
experiencing a disproportionately high impact on their mental health associated with the
pandemic’, with specific figures quoted from the Office of National Statistics’ Student COVID-19
Insights Survey63, noting that ‘63 per cent of students indicated that their well-being and mental
health had worsened since the start of the autumn term 2020’ and that average life satisfaction
63 See
www.ons.gov.uk/peoplepopulationandcommunity/healthandsocialcare/healthandwellbeing/bulletins/coronavir
usandhighereducationstudents/19februaryto1march2021.
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scores for students remain significantly lower than the average ratings of the adult population
as a whole.
173. Given the scale of the problems facing providers, some respondents did call for more
funding to be made available. It was noted that 2021-22 is likely to see further increases in
demand from students for support, due to the ongoing effects of the pandemic, both on new
students and on students that started courses in 2020-21. One respondent noted that ‘this
year, most universities will be welcoming second year students onto campus who have never
been on campus. This means they will be making the transition [to higher education] for the
first time as well.’ Given the likely ongoing future effects of the pandemic, providers also called
for confirmation that the funding stream would be continued into future years.
174. Respondents were supportive of the proposed method to allocate the majority of funding
through a formula. Respondents agreed with our intentions, as expressed in the consultation
document to attempt to minimise the administrative overhead associated with this funding
stream noting that this approach would ‘reduce the administrative burden on providers and
allow funding to be distributed quickly.’
175. Respondents also expressed support for the proposal that any formula be based on the
number of OfS-fundable undergraduate entrants at each provider. It was noted that ‘such
important issues [of student transitions and mental health] benefit from sustained and
consistent funding and for this reason we support the £12m in formula allocation. We also
support the allocation on a pro-rata basis by the headcount of OfS-fundable undergraduate
entrants as reported in HESES20 rather than through individualised data returns. We
understand that student mental health is likely an under-reported issue and therefore support
the allocation being based on all students.’ However, a small number of respondents
questioned this, noting that basing the allocation on the number of students declaring a mental
health issue would allow for greater targeting of the funding to institutions with students having
the greatest need.
176. There was very little support among respondents for allocating part of this funding stream
through a competition. It was noted that a bidding process would tend to disadvantage smaller
providers: ‘Competition-based funding creates significant overheads for institutions and favours
large institutions with central bidding teams.’ It was also noted that such a process would
increase the administrative burden on providers and threaten the quick distribution of support
to students.
177. As with previous questions, some respondents queried whether the additional funding for
this proposal has come at the expense of cuts to other areas (such as performing and creative
arts). Several of these respondents also noted that supporting arts courses would improve
mental health for all (both students and the wider community), but did not evidence this view.
178. A number of themes raised by respondents are out of scope of this consultation and the
funding powers of OfS. These included:
a. The view, expressed by several respondents that funding to support transitions to higher
education would be better focussed earlier in the student journey, to allow students to
develop resilience. Though we recognise the value of such work in supporting students
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before they attend their provider, we feel that there is equal value in making sure that
funding is available to support students in their vital initial transition into higher education.
b. A similar view that providers work closely with the NHS and other local organisations to
provide support for mental health. While not disputing the usefulness of this funding stream,
respondents questioned whether these issues could be better supported in a more global
way through increased funding to the NHS.
OfS response and decisions
179. We welcome the general support from respondents for the proposals on student
transition and mental health. Where providers have raised concerns about the additional
burden of a bidding process, particularly on smaller providers, we would note that we do not
believe this will be an issue for 2021-22. The proposed £3 million of funding to support
national facilities and regulatory initiatives will be used to support existing programmes and
will not involve a further bidding exercise.
180. We recognise that funding could be targeted differently if it were informed by the
numbers of students reporting a mental health condition – indeed, paragraph 70 of our
consultation explained that this was an option we had considered. However, as the purpose
of the funding is to support transition and mental health for all students beginning their
undergraduate studies (including preventative approaches before mental health crises
arise), we believe it right that we count all undergraduate entrants in the formula.
181. A substantial fraction of respondents, particularly those responding in an individual
capacity appear to have misunderstood the meaning of ‘competition’ and ‘formula-based’ in
the question, interpreting this to mean that individual students would be competing for
support, or that support would be assigned to them by formula, rather than through an
assessment of their specific needs. We would like to stress that the proposals refer only to
the method used to determine the amount of funding received by providers. These
institutions will then be able to use their own informed judgement to determine how that
funding can then be best used to support their students.
182. Having regard to the responses received to our consultation and our duties, we confirm
that we will provide an additional £15 million to address student transitions and mental
health in academic year 2021-22. Of the total, we will distribute £3 million to support existing
programmes that are part of our funding for national facilities and regulatory initiatives, and
£12 million through a new formula allocation pro rata to the headcount of undergraduate
entrants reported in HESES20.64
64 For providers that will be funded for the first time in 2021-22 based on data submitted to the HESF21
survey, we will use their forecast undergraduate data for the year. As with other allocations, their allocation
will be recalculated later in the year to reflect the OfS-fundable undergraduate entrants they report in the
HESES21 survey.
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Question 10: To what extent do you agree with the proposal to maintain in cash terms the rate of funding for the nursing, midwifery and allied health supplement, which will increase the total budget to £27 million?
183. Table A11 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
Table A11: Numerical summary of responses to question 10
Respondent type Strongly agree
Tend to agree Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
38 (31.9%) 44 (37.0%) 11 (9.2%) 1 (0.8%) 25 (21.0%)
On behalf of other organisation
20 (12.3%) 40 (24.5%) 5 (3.1%) 2 (1.2%) 96 (58.9%)
As an individual 866 (13.3%) 1956 (30.1%) 405 (6.2%) 364 (5.6%) 2901 (44.7%)
All respondents 924 (13.6%) 2040 (30.1%) 421 (6.2%) 367 (5.4%) 3022 (44.6%)
184. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer
not to say’ are discounted), 79 per cent of respondents agreed with the proposals and 21 per
cent disagreed. We received 1,381 comments in response to this question.
185. Respondents that provided comments were strongly supportive of the proposals to maintain
funding rates for this targeted allocation, with 30 per cent of respondents also calling for an
increase in the funding available for health education. Some respondents requested that any
increase to the rate of funding be in real terms, rather than in cash terms, noting that ‘costs of
delivery will continue to increase for universities, so providing no real term increase will erode
the sustainability of this provision.’
186. Respondents also commented on the increased demand for trained healthcare workers in
light of the pandemic and called for security that funding rates would be maintained in future
years as this would ‘enable security in workforce planning for the NHS.’ Respondents
commented further on the need to ensure that healthcare courses at providers were
adequately supported in the light of government priorities around healthcare, commenting that
‘the number of student nurses and midwives will increase year on year from September 2021
and funding will become stretched’. It was also noted that increased student numbers would
mean providers needing to accommodate a greater number of students on clinical placements,
with calls for ‘urgent attention [by the] Department for Education working with the Department
of Health and Social Care to placement numbers and distribution, to the supply of clinical
teaching staff and to investment in technology and facilities.’
187. Where respondents disagreed with the question (other than when they thought the rate of
funding should be higher) comments were focussed around the proposals being funded
through reductions in other areas, such as the proposed reduction in funding for subjects in
price-group C1.2. Respondents also queried why the nursing, midwifery and allied health
supplement should be protected over strategically important high-cost subjects.
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188. Several respondents, when discussing the increased demand for healthcare courses,
called for increased support for students on these courses. This included calls to reduce (or
abolish) course fees, to reimplement bursaries and grant for students on such courses, and for
additional funding to be made available from the Department of Health and Social Care to
support healthcare education and training. Such measures are outside of the scope of this
consultation and the OfS’s funding powers.
189. A small number of respondents queried why the nursing, midwifery and allied health
supplement only supports students studying on courses that lead to registration in certain
professions but excludes, for example, those studying on courses such as music therapy.
OfS response and decisions
190. We welcome the general support for the proposals. Although our proposal maintains in
cash terms the rates of grant provided through the nursing, midwifery and allied health
supplement, these courses will attract a real-terms increase to the rates of grant provided
through the main high-cost subject funding method. Given the constraints on the funding
available to us and the priorities we are looking to balance, we believe this approach
remains appropriate.
191. As noted in the OfS response on question 2, the list of subjects that attract the
supplement reflects the courses that have, since 2017-18 been supported through the
higher education finance system, but were previously directly supported through Health
Education England. We do not have evidence about how the costs of courses such as
music therapy compare with those other allied health professions and we do not accept that
there are grounds for taking a different approach to them compared with other courses
whose treatment for funding purposes has for many years been informed by TRAC(T) data.
The latter includes other healthcare courses such as pre- and post-registration courses in
medicine and dentistry, as well as post-registration courses in nursing, midwifery and allied
health professions.
192. Having regard to the responses received to our consultation and our duties, we confirm
that we will maintain in cash terms the rates of grant provided through the nursing, midwifery
and allied health supplement for 2021-22. This will increase the budget requirement from
£23 million to £27 million.
Question 11: To what extent do you agree with the proposal to maintain in cash terms the rate of funding for overseas study programmes, but base the allocation on the higher of relevant student numbers in either 2019-20 or 2020-21?
193. Table A12 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
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Table A12: Numerical summary of responses to question 11
Respondent type Strongly agree
Tend to agree Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
38 (32.2%) 44 (37.3%) 6 (5.1%) 4 (3.4%) 26 (22.0%)
On behalf of other organisation
19 (11.7%) 20 (12.3%) 9 (5.5%) 5 (3.1%) 110 (67.5%)
As an individual 590 (9.1%) 1033 (15.9%) 486 (7.5%) 370 (5.7%) 4009 (61.8%)
All respondents 647 (9.6%) 1097 (16.2%) 501 (7.4%) 379 (5.6%) 4145 (61.2%)
194. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer
not to say’ are discounted), 66 per cent of respondents agreed with the proposals and 34 per
cent disagreed. We received 1,086 comments in response to this question.
195. The most common theme, specifically stated by 29 per cent of respondents, noted the
value of the Turing scheme, and the accompanying OfS funding allocation in enabling students
to study abroad. These respondents also commented on the importance of OfS funding to
mitigate any ongoing impact of the UK leaving the EU and the subsequent end to the UK’s
participation in the Erasmus+ scheme.
196. Respondents commented on the importance of ensuring that the Turing scheme and
broader opportunities to study abroad are open to all students, regardless of their economic
background. Commenters noted the value of overseas study to student outcomes, with one
respondent noting:
‘Students who undertake overseas study, even for a relatively short period of time, have
improved attainment in their degree and increased graduate outcomes and so this should
be considered an essential student experience wherever possible.’
The value of overseas study in fostering connections between the UK and the rest of the world
was also noted, along with the opportunity for students to develop language skills and ‘cultural
understanding, key to maintaining Britain’s status in a global context.’
197. Slightly less than 10 per cent of commenters, primarily those providing a response in an
individual capacity, expressed regret at the decision to leave the Erasmus+ scheme. A similar
proportion of respondents called for increased funding to be made available for overseas study,
or for the rate of funding to be maintained in real terms, though these comments were generally
made in light of increased investment from government, rather than in consideration of how
such an increase could be made by adjustment to OfS budgets. A number of respondents
expressed doubts that the proposal to maintain funding rates could be justified in light of
reductions to funding rates in other areas: ‘we believe the funding rate for overseas study
programmes should share the same [year-on-year] increase (or decrease), in cash terms, as
other high-cost subjects (strategically important or otherwise).’
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198. Respondents were substantially in favour of the proposed method to calculate allocations
on the higher of relevant student numbers in either 2019-20 or 2020-21, noting that:
‘The impact of Covid-19 […] is hoped to be a one-year circumstantial effect, and therefore
the proposal to base the allocation on the higher of relevant student numbers in either
2019-20 or 2020-21 will provide much needed financial stability to support the resources
needed to rebuild student levels to pre-Covid-19 levels.’
and that
‘… [the proposal] is fair given it bypasses the disruption caused by COVID-19 whilst
rewarding those providers that have been agile in increasing numbers through alternatives
such as remote learning.’
A small number of respondents disagreed, questioning whether either of the two proposed
years is a sufficiently true representation, and one that ‘seems reasonable to maintain numbers
based on pre-pandemic overseas engagement.’
OfS response and decisions
199. We welcome the general support for the proposals, both for maintaining the rate of
funding and for the proposed calculation method.
200. We appreciate the calls from some respondents to increase the level of OfS funding
available to support overseas study programmes. However, given the constraints on the
funding available to us and the priorities we are looking to balance, we believe our approach
in maintaining the rate of grant remains appropriate.
201. While we note comments that the pandemic may also have affected the number of
students pursuing a year abroad in 2019-20, we do not accept there are grounds for using
more historic data to inform allocations. The 2019-20 student data was reported as part of
the HESES19 return, originally submitted at the end of 2019 and signed off at the beginning
of February 2020. This will have captured all those students that had started a full year
abroad falling entirely within the 2019-20 academic year, plus forecasts of others starting a
year abroad later in the academic year, which were made before the pandemic had taken
hold and government restrictions introduced. We therefore believe the 2019-20 data
adequately represents a pre-pandemic population of year abroad students.
202. Having regard to the responses received to our consultation and our duties, we confirm
that we will maintain in cash terms the rates of grant provided for study years abroad and
that allocations for providers will be based on the higher of the 2019-20 or 2020-21 student
numbers reported as taking such a year.
Question 12: To what extent do you agree with the proposal to maintain in cash terms the budgets for other targeted allocation as proposed in [paragraph 40 of the consultation document]?
203. This question related to the following targeted allocations:
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a. The postgraduate taught supplement.
b. Intensive postgraduate provision.
c. Accelerated full-time undergraduate provision.
d. Very high-cost STEM subjects.
e. Clinical consultants’ pay.
f. Senior academic general practitioners’ pay.
g. NHS pensions’ scheme compensation.
204. Table A13 summarises the extent to which respondents to the consultation agreed or
disagreed with the proposal, or neither.
Table A13: Numerical summary of responses to question 12
Respondent type Strongly agree
Tend to agree
Tend to disagree
Strongly disagree
Don’t know / prefer not to say
On behalf of a registered provider
16 (13.6%) 42 (35.6%) 22 (18.6%) 6 (5.1%) 32 (27.1%)
On behalf of other organisation
5 (3.1%) 13 (8.0%) 13 (8.0%) 8 (4.9%) 124 (76.1%)
As an individual 151 (2.3%) 650 (10.0%) 473 (7.3%) 375 (5.8%) 4835 (74.6%)
All respondents 172 (2.5%) 705 (10.4%) 508 (7.5%) 389 (5.8%) 4991 (73.8%)
205. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer
not to say’ are discounted), 49 per cent of respondents agreed with the proposals and 51 per
cent disagreed. We received 826 comments in response to this question.
206. A substantial number of correspondents expressed general support for the proposals,
noting that that ‘given the overall fixed recurrent funding for 2021-22 we believe maintaining
these budgets in cash terms is a sensible way of allowing additional support for other areas of
funding.’ Commenters also recognised the additional costs and complexity of the activity
supported by OfS targeted allocations and noted that ‘maintaining in cash terms will provide an
element of stability to support on-going provision in these areas.’
207. Support for the overall position was not unqualified, with particular areas of concern being
the reduction in the rates of funding for the targeted allocations that support intensive
postgraduate and accelerated full-time undergraduate provision. It was noted that intensive
postgraduate courses are resource intensive, but ‘produce graduates with the kinds of
advanced skills which employers demand’ and produce graduates that are ‘closer to market in
terms of professional preparation.’ It was noted that a decreased rate of funding for these
targeted allocations might be viewed as ‘inconsistent with other policy priorities […] dis-
incentivising a curriculum innovation that government remains keen to promote.’ It was noted
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that these courses may be of increased value to the economic response to the COVID
pandemic.
208. A few commenters discussed the decision to maintain the three targeted allocations relating
to NHS costs (those for clinical consultant’s pay; senior academic general practitioner’s pay;
and NHS pensions scheme compensation). Calls were made for this funding area to be
revisited, in light of these allocations being ‘frozen for some years now, which is making
teaching of clinical years increasingly difficult to fund. If not for 2021-22, we would hope that
OfS will review this and either merge with the mainstream into mainstream price group 1
funding or find a means to uprate in future years.’ 65 Other commenters queried why these
allocations, given that they total £22 million, had not been subject to reductions, as a way of
mitigating the necessity of reductions to other funding streams.
209. The largest single theme identified focused on perceived unfairness. A quarter of
respondents expressed the view that maintaining the budget for these targeted allocations
should not come at the expense of reductions to funding in other areas, such as the London
weighting or the rate of funding for price group C1.2. Commenters expressed this as a question
of fairness: ‘I have no issue with funding being maintained in real terms, however this approach
should be applied consistently to everyone rather than a discriminatory system of valuing some
people over others.’
OfS response and decisions
210. We note the concerns expressed by respondents on the decrease in funding rates for
the targeted allocations for intensive postgraduate and accelerated full-time undergraduate
provision. As is the case for OfS funding overall, these reductions in funding rates arise
primarily from increased student numbers in 2020-21. To maintain in cash terms the rates of
grant for both allocations would cost an additional £5 million. We recognise that these
courses are important, but they are also areas where providers are able to charge higher
course fees.66 Given the constraints on the funding available to us and the priorities we are
looking to balance, we believe this approach remains appropriate.
211. The very high-cost STEM subjects and the three targeted allocations relating to NHS
costs are not recalculated afresh each year, although there may be increased student or
staff numbers and costs that the allocations support. We agree that these allocations, and
how they contribute alongside high-cost subject funding to support the subjects concerned,
should be reviewed. That is something we intend to do for future years as part of a wider
and more fundamental review of price groups.
212. Our view is that a cut to the budgets for these allocations would be inconsistent with our
broader policy priority to protect funding for STEM subjects and healthcare disciplines.
Maintaining their budgets in cash terms again allows some protection for these targeted
65 We understand the reference to price group 1 to mean price group A, which covers clinical years of study.
66 For full-time undergraduate courses, regulated fee limits are 20 per cent higher for accelerated courses
than for other courses, recognising their additional costs per annum. With the exception of initial teacher
training, postgraduate courses are not subject to regulated fees: intensive postgraduate courses are
predominantly masters degrees.
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allocations, within the overall constraints on our budget. Reducing these budgets as a
means of mitigating the cuts to funding for performing and creative arts and media studies
and for the additional costs of operating in London is not possible, because we are required,
under terms and conditions of grant imposed by the Secretary of State, to implement the
cuts to those other grants.
213. Having regard to the responses received to our consultation and our duties, we confirm
that for 2021-22 we will maintain in cash terms the budgets for the postgraduate taught
supplement and the targeted allocations for intensive postgraduate provision, accelerated
full-time undergraduate provision, very high-cost STEM subjects, clinical consultants’ pay,
senior academic general practitioners’ pay and NHS pensions’ scheme compensation.
Question 13: Do you have any comments about any unintended consequences of these proposals, for example, for particular types of provider or for particular types of student?
214. This question did not ask respondents to agree or disagree to a specific proposal. We
received 4,224 comments in response to this question.
215. There was a substantial degree of overlap with responses to previous questions, with
respondents particularly reiterating concerns about how the proposals will affect arts, music
and culture, both in the higher education sector and more broadly. More than 60 per cent of
comments referenced these concerns.
216. A substantial number of respondents said that the proposals would result in reduced
financial viability for courses and providers, which may result in staff redundancies,
departmental closures, diminished quality, and ultimately worsened student choice in certain
disciplines. This was discussed in reference to reduced funding:
a. For arts courses:
‘Whether it's intended or unintended these proposals would result in the closure of many
arts and humanities courses. Many of these courses have been hit by reduction in student
numbers over the last decade as a direct consequence of prioritising STEM subjects at A
level – and corresponding withdrawal of performing arts courses in schools in general.’
‘The arts ecosystem which includes HE providers and industry is already incredibly fragile
following changes to government policy in education, arts funding, and swathes of closures
following the pandemic. These proposals will put already precarious institutions closer to
closure, and will therefore damage the diversity of the arts in the UK. The arts are vital to
the UK economy and intellectual and creative life, and require increased funding at this
time. The model shows that institutions who lose out are more likely to be those historically
providing arts education, and small institutions with a close connection to arts industry - and
these frequently serve working class and first generation students, as opposed to wealthy
institutions who tend to serve a wealthier student body. Further equality impact
assessments to the arts is urgently needed.’
b. For archaeology courses:
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‘The top four university archaeology departments in the world are all found in the UK. A
blanket cut on this scale would do irreparable damage to countless archaeology
departments (many of which are already hanging on by a thread) and harm our standing in
the world […] In the past 10 years, one university archaeology department has already
been forced to close, another in 2020 had to reduce its staffing by 50 per cent, and
currently the Department of Archaeology at [provider name] is also threatened with closure.
Yet more have scrapped their fieldwork programmes because of budget cuts.’
c. For courses offered by providers in London:
‘The proposed cuts to London weighting could have a material impact on the financial
stability of a significant number of London universities, when taken in addition to the losses
due to the pandemic. The abrupt removal of a large sum from institutional budgets does not
give institutions sufficient time to adjust their resource base or find alternative revenue
sources.’
217. Respondents also commented on the impact of the proposals on students from under-
represented backgrounds and on students with protected characteristics. For most responses,
this reflected the effects noted in the main consultation document:
‘Furthermore, arts courses have a higher-than-average number of students with reported
disabilities and those from POLAR quintiles 1 and 2 – something OfS has acknowledged in
the consultation’.
218. Comments noted that the proposals would reduce the viability of courses or incentivise
providers to reduce their offering in certain areas, and this would reduce the opportunities for
students from under-represented groups to engage in these subjects.
‘There is a risk that universities will move to only offer high-cost subjects programmes for
which they get the most funding. This may have an impact on APPs [access and
participation plans] & disadvantaged students.’
‘The cuts to arts subjects will inevitably lead to Department and programme closures, most
likely at institutions that historically attract students from lower socio-economic backgrounds
and/or from global majority backgrounds. The proposals thus unduly penalise students from
these backgrounds, making the study of arts a space of enormous privilege.’
219. A number of respondents particularly noted that the proposals would affect the viability of
price group C1.2 courses at smaller and more specialist providers, such as further education
colleges. This may result in ‘cold spots’ – geographical areas where higher education (in
general or for specific subjects) is unavailable.
‘We are concerned that increased costs of delivering HE combined with reduced funding
can result in closure of HE at some colleges that will ultimately limit student choice
particularly for mature and part time students who tend to study locally’.
‘OfS needs to assess and evaluate the role of college HE delivery in the cold spots of the
country and also the impact of the void that may result if FE colleges ceased to deliver HE.’
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220. Commuter students were highlighted by a number of respondents as a particularly affected
student group that had less flexibility in their study options, are more likely to be from under-
represented groups and may have financial challenges that effect their ability to study.
‘… for London especially, this means that these students are more likely to be commuters
who travel from their family home into the city. Furthermore, the research shows that being
a commuter student often intersects with being more likely to be the first in their families to
go to university, more likely to be from lower socio-economic areas, and more likely to be
from a black or minority ethnic background’
‘… [commuter students] may find creative arts are no longer provided at their local
institution, so become less likely to study those subjects. This would too, in turn, lead to a
less diverse arts sector.’
221. Respondents commented on the wider value of affected subjects (particularly the arts) to
the economy and the consequences of the proposals on their funding. Several respondents felt
that the proposals sent an unfortunate message about the value of the arts: ‘these cuts also
send a strong message to a wide range of stakeholders that arts-based subjects and specialist
providers are not valued’ and ‘there is a significant risk that this proposal will further destabilise
and reduce access to arts and cultural subjects in secondary phases of education.’
Respondents also repeated comments seen in earlier questions that reductions to arts subjects
at higher education level will affect the pipeline of qualified graduates necessary to maintain
sectors that contribute to the UK economy: ‘Over the medium to longer-term this will reduce
investment in areas where the UK are world leaders, both academically and economically’.
222. A number of comments were made in this vein about the specific value of archaeology to
the economy, given the importance of graduates in this area to the construction industry.
‘We are very concerned that the reduction in costs for archaeology as a subject from £243
to £122 pa will have significant knock-ons. Providers will withdraw further from teaching
archaeology courses and prospective students will consider the potential resourcing of
archaeology courses to be too low for a good outcome’.
‘Commercial archaeology is already suffering from a lack of personnel, any cuts to
university archaeology will shrink an already struggling sector that is currently critical to the
construction industry.’
223. A small number of respondents reiterated comments on the timing for implementation of
these proposals, noting that the short notice will compound any adverse effects for provider
and course viability.
‘To expect institutions that stand to lose significant amounts of funding to adopt new
strategies within such a short time frame is unrealistic and unreasonable. Students applying
to study subjects in the proposed C1.2 price group and/or in London will see their options
curtailed and in some instances activity will need to be discontinued. Whether these
outcomes are unintentional is a question for the government.’
224. Finally, one respondent commented on the possibility that future developments to the
higher education funding system might magnify the effects of the changes being consulted on:
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‘Were these measures to be taken in isolation, the impact is not significant, but if this was
combined with a reduction in fees for certain courses (in line with draft Augar report) then
the combined effect could be that courses such as performing and creative arts would
become far less attractive to institutions’.
OfS response
225. We have noted the arguments presented by many respondents relating to the
sustainability of subjects in the performing and creative arts, media studies and
archaeology; the contribution they make to the economy and society and the benefit they
bring to students who study them, including many from disadvantaged backgrounds.
226. We have also noted the arguments presented by respondents on the impact that the
removal of London weighting may have on the provision of higher education in the capital
and the students who study there, again including many from disadvantaged backgrounds.
227. The terms and conditions that the Secretary of State has applied to OfS grant for
2021-22 mean that we must implement the reduction to the rate of high-cost subject funding
for the performing and creative arts and media studies and cease to vary grant rates based
on the region of the UK in which higher education is offered. If we do not, we may be
required to repay the whole or any part of the grant still held by us to the Department of
Education.
Question 14: Do you have any comments about the potential impact of these proposals on individuals on the basis of their protected characteristics?67
228. This question did not ask respondents to agree or disagree to a specific proposal. We
received 3,856 comments in response to this question. As with question 13, the comments
received showed a substantial overlap with those discussed in previous questions. In particular
respondents reiterated their concerns that reducing the high-cost subject funding rate for price
group C1.2 subjects, and removing London weighting would:
• have a direct negative impact on students with protected characteristics
• reduce the chances of students (both current and prospective) from low-socioeconomic
backgrounds accessing higher education
• have a negative impact on student choice and opportunities when entering, studying and
leaving higher education
• have the potential to reinforce existing barriers which students with protected characteristics
face and reverse access and participation efforts.
229. More than 50 per cent of responses referenced disability and ethnicity. Responses also
referenced impact on students with other protected characteristics, but in much smaller
67 Protected characteristics are defined in Part 11 of the Equality Act as: age; disability; gender
reassignment; pregnancy and maternity; race; religion or belief; sex; sexual orientation. See:
www.legislation.gov.uk/ukpga/2010/15/part/11/chapter/1.
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numbers. As with responses to other questions in this consultation, a substantial proportion of
these responses noted and reflected on the points made in the main consultation document
about the participation of under-represented student groups on arts courses and at providers
studying in London. Such responses particularly reflected points made about the comparatively
high proportions of students: with a reported disability; coming from a minority ethnic
background; coming from POLAR quintiles 1 and 2; and mature students.
‘The consultation document itself has identified most of the concerns we would have, and
the reason to reconsider or pay great attention to some aspects of the proposal. Data which
identifies that subjects in the digital and creative arts attract the highest proportion of
students with disabilities, especially cognitive & learning difficulties and mental health
conditions, as well as recruiting more students from lower participation POLAR wards
strongly suggests that by shifting resource away from these courses we reduce, not
increase the opportunities available to these students.’
230. Respondents argued that cutting funding for affected courses would have a direct negative
impact on the access and participation work providers have been doing to increase diversity
across the higher education sector.
‘The proportion of disabled students in our Faculty of Arts, Design and Media is double that
of our other Faculties. Cutting funding for these subjects in half appears to run contrary to
institutions working on strong Access and Participation work, and these changes are likely
to reduce opportunities in Higher Education for students with these particular
characteristics.’
231. Some responses noted that underrepresented student groups may not be equally well-
represented in affected subjects and courses, but noted that the proposed reductions to
funding would exacerbate such differences:
‘Whilst we recognise that the [sector] has a way to go in increasing its inclusion and
diversity representation, this proposed cut would make it even more challenging for anyone
but the most privileged from being able to access archaeological training and will […]
disproportionately affect the most disadvantaged and excluded demographics in our
society.’
‘The proposals will inevitably impact most severely upon those least represented in the arts
and creative economies. As the consultation acknowledges the arts “are less likely than
average to be mature (aged 21 or over) or to come from a black, Asian or minority ethnic
background” (para. 22) yet the proposals will make studying these subjects much harder
(through, for example, closure of provision or propagating a negative perception as to their
‘value’). This will only serve to exacerbate issues of representation and access, and will
unduly negatively impact individuals on the basis of protected characteristic.’
232. Comments about the effects of the proposal to cut London weighting reflected similar
concerns to those made about reductions in the rate of funding for price group C1.2.
Respondents particularly noted paragraph 48 of the main consultation document, discussing
expected effects on students from a minority ethnic background:
‘London universities have far higher rates of enrolment of students who identify as Black,
Asian, Mixed or Other (52.3 per cent) than the national average (29.2 per cent). AccessHE
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analysis of demographic trends suggests the proportion of ethnic minority students enrolling
in London universities is likely to grow significantly over the next 10 years. This proposals
significantly reduce funding to London universities and consequently on more students with
protected characteristics. Reducing opportunities for ethnic minorities to access high quality
education locally to them is not in the interests of either students or employers.’
233. A small number of providers highlighted specific issues relating to their circumstances:
‘… [we] stand to lose more than 50 per cent of grant funding compared to current levels.
This is a significant reduction in funding that will affect student experience and support at a
provider whose students are drawn largely from the UK, where 21.1 per cent of students
have declared a disability and 47.5 per cent of students are BAME.’
‘The significant cuts in funding resulting from these changes will cause [the arts provider] to
review its provision in all areas, because it will not be possible to sustain the level of
support we currently provide to students. We will of course undertake an internal impact
assessment of any cuts we will have to make to provision, but we cannot guarantee that
such significant loss of income will not impair our ability to provide additional support to
those students who require it. Conservatoire training is by its nature intensive and
expensive and many students require additional support to be able to access the training;
[we have] historically been very successful at raising our own funds to support this work,
but these funds may not be called upon to cover the core costs of training.’
234. A small proportion of respondents, mainly those replying on behalf of providers or other
organisations felt that the proposals would have a positive or no impact on students with
protected characteristics. Positive effects discussed included:
‘the proposed additional funding allocations (£5M for hardship and £12M for mental health
support transitioning to HE), may in turn enable HEIs to better support students with particular
protected characteristics to access and successfully achieve their goals in HE.’
‘The University welcomes the continuation of targeted funding for disadvantaged students and
on improving access and supporting successful student outcomes. By targeting funding in this
way, we feel this is likely to impact positively on students with protected characteristics who are
disproportionately represented in these targeted groups. In particular the ongoing commitment
to the disabled students' premium (including an increase of 2%) is supported and will enhance
the provision given to this cohort of students with this protected characteristic’
235. A small number of respondents mentioned the reduction of funding for the Uni Connect
programme to £40 million in their comments to this question. Reflecting themes raised under
question 7, they expressed concerns that the proposed changes would have ‘significant
implications on the national picture for [widening participation] outreach, support […] and
‘levelling up’ in social mobility’ and that it would ‘have an impact on the work that can be done
in encouraging students from hard to reach backgrounds (including those from certain
ethnicities) in entering Higher Education … [which would] disproportionately affect students
from certain ethnicities.’
236. A high proportion (40 per cent) of respondents asked if a ‘public sector equality data
assessment’ had been undertaken for the proposals.
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237. Although not a protected characteristic, a substantial number of respondents reiterated
concerns raised in question 13 about the effect of the proposals on students from lower-
socioeconomic backgrounds. The main concern in responses which discussed such students
was that the potential reduction in creative courses (following cuts to funding) will make it
harder for students from low socioeconomic backgrounds to access these courses as they may
be ‘priced out’ by richer students, consequently reserving creative subjects for the wealthier
and elite. Respondents also called for students from low-socioeconomic backgrounds to be
added to the OfS’s list of protected characteristics.
OfS response
238. This question invited responses on the impact that the proposals would have on
individuals based on their protected characteristics. Respondents to this question tended to
focus on the impact of our proposal to reduce funding to price group C1.2 on those students
with protected characteristics. As above, since publishing our consultation, the Secretary of
State has imposed terms and conditions of funding in relation to several of our proposals,
including the reduction of funding to price group C1.2. The Secretary of State confirmed to
us that he considered the equality impacts before issuing these terms and conditions of
funding.
239. As we note above, terms and conditions issued under section 74 HERA impose a
statutory obligation on the OfS to distribute funding in a particular way. While we have had
regard to all relevant statutory duties in developing our proposals, we ultimately had to fully
comply with the terms and conditions of funding imposed by the Secretary of State in
arriving at the decisions set out in this document.
240. Where the Secretary of State imposes terms and conditions of funding on the OfS, the
practical effect is that we must comply with them or repay the whole or any part of the grant
still held by us to the Department of Education.
241. Given this, we have focused on the issues raised by respondents to this question on
matters not covered by terms and conditions of funding imposed on the OfS by the
Secretary of State.
242. As in our responses to question 7, we recognise that reductions to the Uni Connect
budget may result in an overall reduction of activity within the programme, but we still expect
Uni Connect programmes to maintain the targeting of their programmes at student groups
that can be helped most, and to maintain their ambition around the number of learners who
will be engaged during 2021-22. A sizeable body of evidence has been generated through
phases one and two of the programme, and we consider that this, along with increased
efficiency, will allow Uni Connect partnerships to minimise the effect of reduced funding on
students.
243. A small number of comments were received expressing concerns about the effect of
‘moving funding away from student premiums’. The budget for the existing student
premiums, excluding Uni Connect and the new premium for student transitions and mental
health, has increased by £5 million, as a result of the provision of additional hardship
funding. The removal of London weighting elements from the student premium calculation
will affect the distribution of the premium total among providers, but this is subject to the
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terms and conditions imposed on us by the Secretary of State, which we are obliged to
follow.
244. As discussed in Table 4, our overall budget distributed to the sector has a slight increase
compared to last year. Providers retain the ability to decide how to best use their overall
income, including from course fees and (within the limits set out in our terms and conditions
of funding) their OfS funding allocations. This would include the ability to best decide how
funding earmarked to support student access and success is targeted.
Question 15: To what extent do you agree with the proposed changes to terms and conditions of grant for 2021-22?
245. This question related to proposed terms and conditions of funding with which providers
would have to comply for the £5 million hardship funding and £12 million formula allocation to
support student transitions and mental health. Table A14 summarises the extent to which
respondents to the consultation agreed or disagreed with the proposal, or neither.
Table A14: Numerical summary of responses to question 15
Respondent type Strongly agree
Tend to agree
Tend to disagree
Strongly disagree
Don’t know / prefer not to
say
On behalf of a registered provider
21 (17.9%) 65 (55.6%) 5 (4.3%) 7 (6.0%) 19 (16.2%)
On behalf of other organisation
7 (4.5%) 21 (13.4%) 5 (3.2%) 15 (9.6%) 109 (69.4%)
As an individual 85 (1.3%) 635 (10.1%) 403 (6.4%) 1009 (16.0%) 4183 (66.2%)
All respondents 113(1.7%) 721 (10.9%) 413 (6.3%) 1031 (15.65%) 4311 (65.43%)
246. Of the respondents that expressed a view (that is, when responses of ‘don’t know / prefer
not to say’ are discounted), 37 per cent of respondents agreed with the proposals and 63 per
cent disagreed. However, of the registered providers to whom the conditions would apply and
that expressed a view (that is, when responses of ‘don’t know / prefer not to say’ are
discounted), 86 per cent agreed and 14 per cent disagreed. We received 810 comments in
response to this question.
247. More than 40 per cent of the responses received for this question either offered no further
comment or did not relate to the terms and conditions of grant that will apply to providers who
receive OfS funding allocations for 2021-22. Instead, respondents used the question as an
opportunity to reinforce and reiterate themes raised in previous questions, such as opposition
to reducing the rate of high-cost subject funding for subjects in price group C1.2. or general
calls for increased levels of funding from the government.
248. In addition, a small minority of respondents seem to have misunderstood the question
being asked. Respondents appeared to:
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• Confuse the use of the word ‘grant’, which in the question refers to the provision of OfS
funding to providers, with maintenance grants made to students.
• Assume that the question was asking for comments on the total budgets made available for
the hardship funding and premium for student transition and mental health allocations
(covered in questions 8 and 9), rather than on the terms and conditions that apply to their
use.
• Assume that the terms and conditions being consulted on were those that might apply to
higher education courses (and the students on these courses).
249. 30 per cent of all comments received were positive on the proposed terms and conditions.
Respondents acknowledged the value of the terms and conditions for the new student hardship
and student transitions and mental health allocations, noting that: ‘[they will] ensure the [new
allocations] are used on projects aimed at student hardship and mental health. It is necessary
for the implementation of these funds’ and that ‘It isn’t unreasonable for the OfS to retain the
right to reclaim unspent monies, distributed for a specific purpose, if those monies have not
been spent for that said purpose, within the period specified.’
250. Though respondents were understanding of the need to apply terms and conditions to the
use of the new funding allocations, a number of respondents qualified their support, noting that
as a principle, it is preferable for providers to have as much flexibility as possible in how
funding, particularly student premium funding, should be spent. One provider noted:
‘While we recognise the necessity to earmark funding for specific national priorities, such as
mental health (above), we generally oppose the principle of direct earmarking or other
restrictions as far as possible. This is because we feel institutions should be allowed
discretion as to how funds are applied to find the most appropriate ways to tackle these
issues which may include expenditure on infrastructure and other costs that may not be
direct.’
251. Other respondents struck the same note, noting that they appreciated the specific aims of
the new funding allocations, but that in general it was preferable for funding to be distributed
through the main student premium allocations, with the ability for individual providers to decide
on its best use, bearing in mind their access and participation plans and student
circumstances.
252. Some respondents commented on the increased burden on monitoring the use of these
funds. Commenters accepted that more specific monitoring would be appropriate for these
funds, given their intended use:
‘Given these additional allocations have been targeted to address very specific challenges
currently facing students and universities it is appropriate for there to be more direct
reporting on the use of these funds.’
However, respondents also called for any monitoring mechanism to be as light touch as
possible, given the expense and additional burden of ensuring compliance:
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‘OfS should continue to be mindful of striking a balance between the requirements of
monitoring and the additional costs that may be incurred by providers for additional external
auditing.’
253. On the same theme, respondents called for more guidance on the use and monitoring of
these funds to be published, to allow providers to ensure that all funding is properly allocated.
One respondent noted that it would be appropriate for any such monitoring to take place as
part of the OfS’ annual finance return.
254. Continuing on the theme of flexibility in the use of OfS grant, particularly for the new funding
allocations, a small number of respondents called for flexibility in any requirement for use of the
funding within a certain time period. One comment noted that: ‘the definition of the academic
year will need to take into account the fact that providers may have flexible entry points to
courses and that a suitable window needs to take place to allow institutions to disburse funds
before they are considered “unspent”’. Another called for allowing a certain proportion of any
unspent funding to be ‘rolled over’ into subsequent years.
255. Finally, one respondent expressed the view that:
‘We do not find the hardship funding terms to be in line with this current consultation. This is
with reference to the requirement to distribute the funding directly to students, which has
not been considered in paragraph 65. We find that the requirement for distribution to
students has only appeared in the terms and conditions of funding thus this point has not
been consulted upon. We disagree with this point.’
OfS response and decisions
256. Noting the number of respondents (particularly those responding in an individual
capacity) that we feel had misinterpreted the basis for this question, we would take the
opportunity to clarify that the terms and conditions referred to in this question apply to higher
education providers registered with the OfS and refer to the use of the funding allocations
they receive from us. They do not refer to students at those providers.
257. We welcome the positive comments on the terms and conditions made by providers, and
note the comments made about the advantages in providing as much flexibility as possible
in allowing providers to determine the best use of funding allocations to support their
students.
258. The allocation of hardship funding for 2021-22 has a distinct purpose, specifically to help
providers support students that are in hardship, with support intended to be responsive to
the needs of those students. As such, we believe it is important to specify that this funding
must be distributed directly to students, though providers have freedom to decide on the
most appropriate method for that distribution, to support those in greatest need. The funding
must be used within the 2021-22 academic year – we believe this gives providers plenty of
time to disburse the funding to students facing hardship during the year and, as such, we do
not accept that it would be in students’ interests to allow providers to roll it over into later
years.
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259. The allocation for student transitions and mental health is to support students’ transition
into higher education, addressing the challenges to student mental health for those at the
beginning of their undergraduate studies, including through supportive and preventative
measures that help to maintain good mental health and prevent more serious problems
arising. Providers do have flexibility in determining what activities and services they provide
for students that will best meet this purpose. Given this focus on transition into higher
education, we expect providers to use the funding in full during 2021-22, rather roll it into
subsequent years.
260. We accept the desirability of minimising the burden of any monitoring of this funding,
subject to gaining assurance that terms and conditions have been met. We intend that such
monitoring will take place through existing reporting mechanisms, including through
providers’ audited financial statements, to minimise any burden. We will confirm monitoring
arrangements separately.
261. Having regard to the responses received to our consultation and our duties, we confirm
that:
a) Funding identified in our grant allocations to providers as to address hardship will be
earmarked for distribution in the academic year to students aiming for a higher education
qualification who are facing hardship, particularly where it is needed to support their
continuation of study and successful outcomes. It must not be used to meet providers’ own
costs. We reserve the right to recover any hardship funding that is not used for the purposes
intended.
b) The premium for student transition and mental health will be earmarked for activities and
services of providers that support students transitioning into higher education, particularly to
address the challenges that this can present for mental health.
Question 16: Do you have any other comments on the proposals in this document?
262. This question did not ask respondents to agree or disagree to a specific proposal. We
received 2,410 comments in response to this question. The majority of respondents to this
question used their comments to reiterate key concerns with the proposals raised earlier in the
consultation. In particular:
a. More than 70 per cent of respondents used their comments as an opportunity to
restate their opposition to any cuts to funding for the subjects in price group C1.2
and to protect the larger arts sector.
b. Around 5 per cent of respondents commented on issues of timing with the
consultation, noting that providers have been given only a short time to prepare for
the impact of the proposed changes to our funding methods before the beginning of
the 2021-22 academic year: ‘The notice given by the proposals is far too short to
enable Higher Education providers to plan effectively for September 2021.’
c. Around 5 per cent of respondents commented on concerns about the impact of
proposals on students with protected characteristics or on providers’ access and
participation work.
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‘Some of the proposals within this consultation pose a risk to the attainment of access and
participation plan targets, and although impacts may not be felt immediately, we will be
answering to them in the years ahead […] Any reduction in funding that impacts on
outreach (such as Uni Connect) or enablement once in HE, has the potential to widen the
gap in attainment and progression rather than decrease or eliminate it.’
d. A small number of respondents reflected on concerns about the removal of London
weighting, particularly around the predicted financial effect for providers based in
the capital.
263. Another significant theme was that the consultation had not included questions regarding
the targeted allocation for world-leading specialist providers. The responses were aware of the
continuation of the £43 million, the £5 million uplift for the existing recipients and the further
unallocated £5 million for 2021-22. The responses fell into three areas of concern.
a. Those who received the funding and wished it to continue with some of these
raising concerns about how we progress the review of this funding.
‘We note and support that OfS are committed to carrying out a full review of world-leading
specialist […] provider funding in 2021 to inform funding from 2022-23. It is vital that the UK
must maintain its position in the world of specialist providers in the performing arts and
thereby supporting the UK theatre and film industries which are so vital to the economy,
culture, society and wellbeing.’
b. Those who believe they meet the eligibility criteria under the previous HEFCE
approach, either in 2015 or have become eligible since 2015, and believe the
current allocation unfairly excludes them from specialist provider funding.
‘The consultation presages a further consultation on this process and anticipates
“comprehensive submissions” in due course. This targeted allocation is critical if the UK’s
world-class specialist providers are to thrive and we welcome recognition by the OfS that a
consultation on the process needs to takes place as soon as possible. However, because
research, KE [knowledge exchange] and practice at a number of specialist HEIs has
dramatically changed in the last five years those institutions who currently receive this
[specialist institutional funding] should also be reviewed. It does not seem equitable to have
simply allocated a further £5 million to existing recipients without further review? In our
opinion the OfS should reconsider its approach to distributing [funding for specialist
providers].’
c. Multi-faculty providers and other stakeholder groupings which are frustrated that this
funding continues, and indeed was enhanced, and feel the premise of the funding is
unfair given the general reduction in C1.2 funding. They wish to have a fundamental
review of this funding allocation as soon as possible. These included providers who
have long objected to the existing criteria.
‘These proposals do not reflect the fact that not all Conservatoires are in specialist
institutions. While there will be a separate consultation on specialist Conservatoire funding,
please consider Conservatoires which form part of an institution’s wider provision.’
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264. Around 2 per cent of respondents commented on elements of the consultation that
appeared to discount or conflict with other government policies, such as the Home Office
priority immigration lists of shortage occupations. Respondents with an interest in Archaeology,
either from provider departments or stakeholder bodies, noted the requirement for professional
archaeologists in major infrastructure projects.
‘Archaeology graduates are crucial to the sustainability of the UK workforce in
development-led archaeology. As a recognised construction skill, archaeology is a part of
the supply chain for housing development and infrastructure and is essential to meet
planning policy requirements to deliver sustainable development. As such, archaeology is a
contributor to this key Government priority area.’
265. Other respondents referenced Arts and Humanities Research Council research on the
contribution of arts to the economy. Some respondents indicated they would like to see the
evidence used to support the ‘strategic important priorities’ noted in the consultation and DfE
guidance.
266. There were a range of one-off responses. One respondent noted that ‘Jisc continues to
accrue income and we believe that these other areas of funding should be reviewed.’ Another
was concerned that any government policy changes to course fees could well overshadow the
recurrent grant changes.
OfS response
267. We have noted the views expressed by respondents relating to funding for the
performing and creative arts, media studies and archaeology and for London weighting. We
have addressed these subjects in our response to earlier questions in this document.
268. We acknowledge the range of strong views about funding for world-leading specialist
providers. As noted in our main consultation document, the proposed changes to this
funding for 2021-22 in our consultation document reflect requirements that the Secretary of
State has placed on us under terms and conditions of grant. If we do not, we may be
required to repay the whole or any part of the grant still held by us to the Department of
Education.. We would reiterate that we have committed to a full review of world-leading
specialist provider funding this year, which will be subject to a separate consultation. We
would encourage all with views on this issue to respond to that consultation and reiterate
their views. We hope to publish a timetable for work on the specialist review shortly.
269. Our consultation set out our plans to maintain in cash terms funding for national facilities
and regulatory initiatives (which primarily covers funding for Challenge Competitions, Jisc
and the National Students Survey). In proposing this for 2021-22, we were mindful that this
budget was subject to a substantial reduction from an originally planned £40 million in
2019-20 to £21 million in 2020-21, including a £13 million reduction in recurrent funding for
Jisc.68 Given the scale of the changes that were implemented last year, which sought to
68 See: www.officeforstudents.org.uk/publications/funding-for-2020-21-ofs-board-decisions/.
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protect as far as possible the funding allocated to providers, we do not consider it
appropriate to make further reductions from this budget for 2021-22.
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